Third, price whatever remains. This is the move that does the most work. Across the archive the office has quoted $385,131.42 and collected $0. The quotes are not arbitrary; they are itemized, arithmetically consistent, and tied to a published hourly rate with fringe. That is what makes them effective. A number that looks like a receipt is much harder to characterize as a refusal than a bare denial, even when the practical effect is identical.
Fourth, build the price out of the office's own review time. In the 26-131 itemization, $66.13 of the $82.66 total — eighty percent — is the cost of separating exempt from non-exempt material in the office's own files. The requester is not paying for copies. Copying is listed at $0.00. The requester is paying for the office to read what the office already has. That is permitted under the statute when the volume justifies it, and the volume is asserted rather than shown. On the 25-241 itemization the same move produces a form that does not add up: the line items total $18,009.00 while the printed subtotal reads $1,863.00 and the deposit $931.50, a $16,146.00 gap on the face of the county’s own paperwork. A requester who wants to challenge an excess fee under MCL 15.240a has to know which number is being charged, and the form does not say.
Fifth, leave the waiver undecided. The public-interest waiver is the one part of the fee process where the office has to write down a reason. On the 26-131 itemization the section is present, the box is unchecked, and the subtotal line is blank. Declining a waiver with reasons creates a reviewable decision. Leaving the section blank creates nothing to review, and the full fee stands. This is the quietest move in the sequence and, on this record, the most revealing.
Sixth, require a deposit and restart the clock. A 50 percent deposit is lawful when the estimated fee exceeds $50. It also converts a five-day response obligation into a thirty-day production obligation that begins only when the money arrives. The requester who cannot pay does not get a denial that can be appealed. The requester gets a file that stays open, and the record shows no production.
Seventh, let the appeal affirm. Every appeal in this archive was upheld by the Delta County Board of Commissioners. The written decisions are short, restate the coordinator's conclusion, and in at least one instance were issued the same day the appeal was received. An appeal that always affirms is not a check on the first decision. It is the same decision with a second signature.
Eighth, when the record is held elsewhere, say so — and stop there. FOIA 25-202 is the clearest example in the archive of an answer that is both accurate and incomplete. The office certified that it holds no RFP, no vendor bid and no purchase order for the case-management system it runs, and it explained why: the association administered the procurement. That explanation is true, and it is also the end of the county’s obligation. Nothing in the statute requires a public body to obtain a record from another public body, or to tell the requester which body to ask. The result is a purchase in the millions with no procurement file in the county’s hands, and a requester who has to know that PAAM exists before he can ask the next question. Diffusion is not evasion. It is the same outcome by a quieter route, and it is the reason the next request in this line has to be aimed at the association rather than at the county.
Ninth, answer precisely when the request names the document, and let the broader question stand. FOIA 25-234 named four laboratory reports and got all four in a week, free, unredacted. FOIA 25-130 asked for “defendant name(s)” and “the final disposition(s)” and got one defendant’s paperwork and silence about the other. Both requests concern the same April 2024 investigation. The office is not unable to produce records from that file; it produces them readily when the request hands it a list of documents. The move is to reward specificity and let generality stall, so that the requester who does not already know what exists receives the least. That is lawful, and it is the reason the working list behind this site keeps getting narrower: the way through is to name the document.
Tenth, certify that the data does not exist, then quote a price to rebuild it. FOIA 25-257 is the purest form of the move. The office answered three paragraphs of a plea-and-disposition request with three certificates of nonexistence, then wrote that “the data related to the request is available” and priced a hand reconstruction at $19,840 for five years of cases. The certificate and the estimate are not offered as alternatives to choose between; they are stapled together in one letter, so that the requester who reads only the certificate stops, and the requester who reads on is told the answer exists but will cost nearly twenty thousand dollars. Neither reading produces the number. The office’s own case-management system, live since June 2024, is the thing that could produce it, and the letter never says why it cannot.
Eleventh, reuse the last invoice. FOIA 25-254 arrived one day after the 25-244 itemization was signed, and it came back with that same itemization: $49,680 to locate, $24,840 to redact, $74,520 total, the same 8,000 and 4,000 increments, and the same “6 YEARS requested” justification — for a request that covers 2022 to present rather than 2020 to 2025. The invoice was not costed for the request in front of the office. It was carried forward. That is the move in its barest form: the price is not a computation about this request, it is a document about the last one, and it is issued before the new request is even read. It also explains why the arithmetic can be wrong by a factor of fifteen and still look authoritative. A copied invoice is not checked against the volumes it claims to price, because it was never built from them. The requester sees a number with a receipt behind it and has no way to know, from the face of the document, that the receipt belongs to someone else.
Twelfth, bill the same review twice. FOIA 25-277 and 25-278 arrived together and were answered together, and the office issued two itemizations for them on the same day: $34,720.00 and $23,146.66, $57,866.66 in all, for a single review of the same roughly 4,000 files. The office was not confused about this. Every line of the second itemization carries a footnote saying that if the first estimate is paid, the documents in the second request “would be captured in that review, making this estimate moot.” Having written that, the office issued the second invoice anyway. The move is subtle because each invoice, read alone, looks like a normal estimate for a normal request. It only becomes visible when the two are read side by side, which is exactly what a requester filing one request at a time will never do. The pair is the point: the office answers like requests alike, and then charges for each as though the other did not exist.
Thirteenth, produce the number only when it lives somewhere else. FOIA 26-35 asked for the January 2026 plea-agreement count and got it — 52, free, in five business days — because the answer could be taken from the District and Circuit Court dockets. Five days earlier, FOIA 26-28 asked for a different aggregate and was told no responsive record existed, with a $1,653.33 invoice attached, because that answer would have had to come out of the office’s own migrated files. The legal sentence was the same in both letters. The outcome turned on the storage location. This is the move that makes the others coherent: the office is not unable to count, and the archive’s certificates are not all false. It counts when the count is cheap and public, and it certifies when the count would require reading its own records. The 85 minutes the office reported for the 26-35 count — about 1.63 minutes per plea — is the only measured labor time in the archive, and it sits beside per-file estimates of 20, 14 and 5 minutes that have never been measured at all.
Fourteenth, when nothing else fits, say the records were already given. FOIA 26-290 answered five of six items by calling each one “granted” and then withholding it under Densmore, on the ground that the same records had been produced in FOIA 25-279. That production, already on this site, contains no responsive documents: a denial, a blank appeal form, a policy notice and three invoices totalling $34,673.79. The letter names no page of it. The move works because the claim is unverifiable from the response itself — the requester has to go back to a packet he received months earlier and reconstruct what was in it to discover that the premise is false — and because a refusal framed as a filing-cabinet fact reads as administrative housekeeping rather than as a denial. FOIA 26-292 uses the same move with two earlier request numbers, and FOIA 26-30 used it with eight named documents, two of which appear in neither of the requests it cites. The pattern across the three is a citation to a request number in place of a citation to a page. One is checkable. The other is not.