1. Time limit to file an appeal

Alabama has no provision for administratively appealing denials of access to public records.

Not applicable.

(This section is blank. See the point above.)

The Act does not require or otherwise provide for administrative appeals.

Any adversely affected party may petition for rehearing of a proposed decision to the (board, commission, director) within 20 days after issuance of the final agency decision. Iowa Code § 17A.16(2).

Not applicable because there are no provisions for appealing a denial of requested records.

The Act does not provide for administrative appeal.

The statute does not indicate how long a requester has to submit an appeal to the Public Access Ombudsman for mediation. If mediation fails to resolve the matter, the requester has 30 days following receipt of the Ombudsman’s final determination to file a complaint to the PIA Compliance Board. GP § 4-1A-05(b)(5).

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).

A requestor has 60 calendar days from the date of the custodian’s denial to challenge that denial via a complaint to the Government Records Council.  N.J.A.C. 5:105-2.1.  If the requestor wishes to challenge the denial in court, they have 45 days from the date of the custodian's denial to file an action in Superior Court.  See Mason v. City of Hoboken, 196 N.J. 51 (2008).

There is no statutory or case law guidance on this issue.

Not applicable.

Appeals must be filed within 15 business days of the mailing date of the agency’s response or within 15 business days of a deemed denial. 65 Pa. C.S.A. § 67.1101(a)(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).