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Quatrine v. MacKinaw City Public Schools

Citations: 514 N.W.2d 254; 204 Mich. App. 342Docket: Docket 143626, 143627

Court: Michigan Court of Appeals; March 22, 1994; Michigan; State Appellate Court

Narrative Opinion Summary

Consolidated appeals in Quatrine v. Mackinaw City Public Schools and Curley v. Cheboygan Area Schools involve plaintiffs contesting circuit court orders that granted partial summary disposition to defendants and dismissed claims under the Freedom of Information Act (FOIA). The Michigan Court of Appeals affirmed the circuit court's decision, citing the lack of written parental consent for the release of requested records as a violation of MCL 15.243(1)(e) and 20 USC 1232g(b)(1) and (2). Additionally, the court upheld the trial court's discretion in denying both plaintiffs' and defendants' requests for attorney fees and costs, referencing MCL 15.240(4) and MCL 600.2591(3)(b). The decision was delivered by a panel including Sawyer, Fitzgerald, and D.A. Roberson.

Legal Issues Addressed

Discretion in Awarding Attorney Fees and Costs

Application: The trial court's discretion was upheld in denying requests for attorney fees and costs, indicating that such decisions are within the court's authority under the relevant statutes.

Reasoning: Additionally, the court upheld the trial court's discretion in denying both plaintiffs' and defendants' requests for attorney fees and costs, referencing MCL 15.240(4) and MCL 600.2591(3)(b).

Freedom of Information Act and Parental Consent

Application: The court found that the lack of written parental consent for the release of requested records justified the dismissal of the FOIA claims.

Reasoning: The Michigan Court of Appeals affirmed the circuit court's decision, citing the lack of written parental consent for the release of requested records as a violation of MCL 15.243(1)(e) and 20 USC 1232g(b)(1) and (2).