4. Investigatory records.

Internal investigations were exempt from disclosure because otherwise, “employees are reluctant to give statements about the actions of other employees.”  Kent County Deputy Sheriffs Association v. Kent County Sheriff, 463 Mich. 353 616 N.W.2d 677 (2000).  Internal affairs investigatory records fall within the meaning of the term “personnel record of law enforcement” as used in the FOIA.  Newark Morning Ledger Company v. Saginaw County Sheriff, 204 Mich. App. 215, 514 N.W. 2d 213 (1994).  To show that disclosure of investigation record would interfere with the enforcement proceedings, “the government must show, by more than a conclusory statement, how the particular kinds of records would interfere with a pending enforcement investigation.”  Evening News, supra 417 Mich. at 497.  See Mich. Comp. Laws § 15.231.