Prins v. Michigan State Police, 291 Mich. App. 586

Prins requested in-car video records from the May 4, 2008 traffic stop by the Michigan State Police, submitted July 22, 2008.
The State Police denied the FOIA request on July 26, 2008, stating any in-car video was no longer available and only kept 30 days.
The denial envelope bore a July 29, 2008 postmark, indicating mailing occurred on that date.
Elliott appeared at a hearing on October 29, 2008, and the videotape of the stop was produced by the prosecutor.
Prins filed suit in the Ionia Circuit Court on January 26, 2009, seeking to compel disclosure under FOIA.
The circuit court granted summary disposition to the State Police, and the Michigan Supreme Court held mailing triggers the 180-day period and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the 180-day limit commence under FOIA?	Prins argues mailing starts the period.	State Police argues the period starts on the denial letter date written July 26, 2008.	Mailing triggers the 180-day period.

Gillie v Genesee Co Treasurer, 277 Mich App 333 (2007) (statutory timing and notice principles informing limitations analysis)
Detroit v 19675 Hasse, 258 Mich App 438 (2003) (timeliness and limitations reviewed de novo)
Bloomfield Charter Twp v Oakland Co Clerk, 253 Mich App 1 (2002) (statutory construction and harmonization of acts)
Farrington v Total Petroleum, Inc, 442 Mich 201 (1993) (legislative intent and plain meaning guiding interpretation)
People v Blunt, 282 Mich App 81 (2009) (responding to allegations and pleading rules in context of defenses)
Grand Rapids v Crocker, 219 Mich 178 (1922) (harmonious statutory construction within act)
In re Petition of Attorney General for Investigative Subpoenas, 282 Mich App 585 (2009) (statutory interpretation and deference to legislative intent)
McCracken v Detroit, 291 Mich App 522 (2011) (pleadings and affirmative defenses; response requirements)