At issue in Bafna v Echo Valley Condominium Association (unpublished opinion of the Michigan Court of Appeals) was an owner’s right to inspect condominium association records. The owner requested to inspect seven records, but the Association denied the requests. The owner filed suit. The Association defended on the basis that the co-owner had not stated a proper purpose, as required by MCL 450.2487, for the requests. The court found that the Plaintiff’s requests, although unclear, stated a proper purpose and entered judgment for the Plaintiff.
On appeal, the Michigan Court of Appeals affirmed, finding that it was proper for the trial court to review the requests for records in light of the allegations made in Plaintiff’s complaint, which helped clarify Plaintiff’s requests. The court affirmed that “proper purpose” is a relatively low bar; in so holding, the court stated “we can perceive no legitimate reason why any corporation would find it permissible to withhold its corporate Board meeting minutes from one of its shareholders/members."