No appeal is possible until custodian denies the request or fails to comply “with any provision of 950 . 32.00” – presumably meaning, in the typical case, that the 10-day response period has lapsed without a response. G.L. c. 66, § 10(b) (“fails to comply”); 950 32.08(2). An appeal to the Supervisor must be made “within 90 days,” a period that – according to a publication from the Secretary of the Commonwealth – runs from the date of the requester’s “original request.” See 950 32.08(2) and Guide to Mass. Pub. Rec. Law (Sec’y of State, rev. March 2009), “Frequently Asked Questions,” at 1.
There is no stated time limit for appealing an “adverse determination” by a custodian to the agency head. On appeal to the head of the agency, he or she has five business days to issue a decision. 1 V.S.A. § 318(c)(1). The five-day appeal response period may be extended up to ten working days by written certification that one (or more) of three “unusual circumstances” exist: (1) need to search or collect records from field offices; (2) need to search or collect voluminous records; or (3) need to consult with another agency. See 12 V.S.A. § 318(b)(5).
A requester has at least 3 years after a request is denied to file a mandamus action challenging the denial. Wis. Stat. § 893.93 (1m). In general, parties have 90 days (45 if a notice of entry is given) to appeal a final order or judgment of a circuit court. Wis. Stat. § 808.04(1). When an authority provides notice to a record subject under Wis. Stat. §19.356, however, the subject has 10 days from receipt of the notice to “appeal” the authority’s decision to release records. Wis. Stat. § 19.356(4).