American Civil Liberties Union of Michigan v. Calhoun County

Summary

The court held that a federal regulation cannot exempt public records from disclosure under the Freedom of Information Act provision allowing exemptions for records exempted by statute. Because the regulation was not a statute and the statutory language was unambiguous, the court reversed the Court of Appeals and remanded for further proceedings. The court also overruled prior decisions to the extent they treated regulations as statutes under that provision.