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” of the date of the response of the records access officer. See 950 32.08(1)(d); Guide to Mass. Pub. Rec. Law at 73 (Sec’y of State, rev. Mar. 2020), https://www.sec.state.ma.us/pre/prepdf/guide.pdf.
A requesting party may, within 180 days of a public body’s final determination, initiate an action in a state circuit court to compel the public body’s disclosure of the public records. Mich. Comp. Laws § 15.240(1)(b).
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).