Justia Michigan Supreme Court Opinion Summaries

A prisoner was observed by a corrections officer receiving a crumpled piece of paper from another inmate. The officer demanded the prisoner hand over the paper, which contained two orange strips later identified as Suboxone, a controlled substance. The prisoner did not have a prescription for Suboxone. Initially, the prisoner tested positive for Suboxone, but a retest was negative. The prisoner was charged with being a prisoner in possession of a controlled substance (PPCS).The 85th District Court bound the prisoner over for trial, concluding there was sufficient evidence for probable cause without ruling on whether PPCS required a mens rea element. The Manistee Circuit Court denied the prisoner's motion to include a mens rea element in the jury instructions, relying on a previous case, People v Ramsdell, which held PPCS to be a strict-liability offense. The Court of Appeals affirmed the conviction, agreeing that PPCS is a strict-liability crime.The Michigan Supreme Court reviewed the case to determine if PPCS is a strict-liability offense or if it requires a mens rea element. The Court held that MCL 800.281(4) does not plainly impose strict liability and that MCL 8.9(3) applies, requiring the prosecution to prove that the defendant acted with intent, knowledge, or recklessness. The Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with this opinion. View "People v. Tadgerson" on Justia Law

Plaintiffs, who owned real property in Southfield, Michigan, became delinquent on their property taxes between 2012 and 2014. Oakland County foreclosed on their properties under the General Property Tax Act (GPTA). The plaintiffs had the opportunity to redeem their properties by paying the delinquent taxes, but they failed to do so. Consequently, the properties were foreclosed, and the city of Southfield exercised its right of first refusal to purchase the properties for the minimum bid, which included the unpaid taxes and associated fees. The properties were then conveyed to the Southfield Neighborhood Revitalization Initiative (SNRI).The plaintiffs filed a class action lawsuit in the Oakland Circuit Court, alleging violations of their constitutional rights, including the Takings Clauses of the Michigan and United States Constitutions. The trial court granted summary disposition in favor of the defendants, citing lack of jurisdiction, lack of standing, and res judicata. The Michigan Court of Appeals affirmed the trial court's decision. However, the Michigan Supreme Court vacated the Court of Appeals' decision and remanded the case for reconsideration in light of its decision in Rafaeli, LLC v Oakland Co, which held that retaining surplus proceeds from tax-foreclosure sales violated the Takings Clause of the Michigan Constitution.On remand, the trial court again granted summary disposition to the defendants, but the Court of Appeals reversed in part, holding that Rafaeli applied retroactively and that the plaintiffs had valid takings claims. The Michigan Supreme Court reviewed the case and held that a taking occurs when a governmental unit retains property without offering it for public sale and the value of the property exceeds the amount owed in taxes and fees. The Court also held that MCL 211.78m, as amended, applies prospectively, while MCL 211.78t applies retroactively but does not govern this case. The case was remanded to the trial court for further proceedings. View "Jackson v. Southfield Neighborhood Revitalization Initiative" on Justia Law

Carl T. Masi was charged with multiple counts of first-degree and second-degree criminal sexual conduct involving three minors, AU, SU, and MU, who alleged that Masi began sexually assaulting them when they started living with him. Masi sought to introduce evidence related to the complainants' sexual histories, specifically that AU had viewed pornography during prior sexual abuse by her uncle. The trial court denied Masi's motion, ruling that this evidence was inadmissible under the rape-shield statute, MCL 750.520j, and People v Morse, because there was no conviction related to the prior abuse.The Michigan Court of Appeals affirmed the trial court's decision, holding that evidence of AU viewing pornography during prior sexual abuse was "sexual conduct" under the rape-shield statute and thus inadmissible under Morse. Masi then sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court reviewed the case and held that the plain meaning of "sexual conduct" in the rape-shield statute includes both voluntary and involuntary behavior, thus encompassing nonvolitional acts such as involuntarily viewing pornography during sexual abuse. The Court overruled Morse to the extent that it required a conviction for prior sexual conduct to be admissible. Instead, the Court established a new standard requiring an in camera evidentiary hearing to determine the admissibility of such evidence based on specific factors, including whether the prior act occurred, its similarity to the current allegations, its relevance, necessity to the defense, and whether its probative value outweighs its prejudicial effect.The Michigan Supreme Court affirmed in part and vacated in part the lower courts' decisions and remanded the case to the Macomb Circuit Court to apply the new standard in an in camera hearing. View "People v. Masi" on Justia Law

Jose Cruz-Muniz and Sandra Cruz were injured in a car accident in 2018 and received treatment from C-Spine Orthopedics, PLLC. They assigned their rights to seek personal protection insurance (PIP) benefits from Progressive Michigan Insurance Company to C-Spine. C-Spine then assigned its accounts receivable, including the claims for unpaid benefits, to several factoring companies. Progressive argued that C-Spine lacked standing to seek payment because it had assigned its rights to the factoring companies. C-Spine countered with signed counter-assignments from the factoring companies, purportedly restoring its right to bring suits. The trial court initially denied Progressive's motion but later granted it, concluding that C-Spine lacked standing when the complaints were filed.In a separate case, Parie Wallace was injured in a bus accident and received treatment from several providers, including C-Spine. Wallace assigned her rights to seek PIP benefits to these providers. She later filed a lawsuit against Suburban Mobility Authority for Regional Transportation (SMART) seeking payment of PIP benefits. SMART argued that Wallace could not bring the action because she had assigned her rights to the providers. The trial court allowed Wallace to obtain revocations of the assignments, which she did, and then denied SMART's motion for summary disposition. The Court of Appeals reversed, holding that Wallace was not the real party in interest when she filed her complaint and that her claims were barred by the one-year-back rule.The Michigan Supreme Court held that both C-Spine and Wallace had standing to file their lawsuits but were not the real parties in interest at the time they filed suit because they had assigned their claims. The Court ruled that defects in real party in interest status could be cured after filing a lawsuit. In C-Spine's case, the Court of Appeals' judgment was affirmed on alternate grounds, and the case was remanded to the trial court for further proceedings. In Wallace's case, the Court of Appeals' judgment was affirmed in part, reversed in part, and vacated in part, and the case was remanded for the trial court to consider whether equitable rescission was warranted and whether the real party in interest defect could be cured. View "C-Spine Orthopedics PLLC v. Progressive Michigan Insurance Company" on Justia Law

C-Spine Orthopedics, PLLC, filed two actions in the Macomb Circuit Court against Progressive Michigan Insurance Company to recover personal protection insurance (PIP) benefits for care provided to Jose Cruz-Muniz and Sandra Cruz, who were injured in a 2018 car accident. Jose and Sandra assigned their rights to seek PIP benefits to C-Spine, which then assigned its accounts receivable, including these claims, to factoring companies. Progressive moved for summary disposition, arguing C-Spine lacked standing as it had assigned its rights. The trial court initially denied but later granted the motion, concluding C-Spine lacked standing when the complaints were filed. The Court of Appeals reversed, holding C-Spine retained its claims for PIP benefits under MCL 500.3112.Parie Wallace filed an action in the Wayne Circuit Court against Suburban Mobility Authority for Regional Transportation (SMART) seeking PIP benefits after being injured in a bus accident. Wallace assigned her rights to PIP benefits to her medical providers. SMART moved for summary disposition, arguing Wallace could not bring the action due to the assignments. The trial court allowed Wallace to obtain revocations of the assignments, which she did, and then denied SMART’s motion. The Court of Appeals reversed, holding Wallace was not the real party in interest when she filed her complaint and that her claims were barred by the one-year-back rule.The Michigan Supreme Court held that both C-Spine and Wallace had standing to file their lawsuits but were not real parties in interest at the time of filing due to their assignments. The Court ruled that defects in real party in interest status could be cured after filing. In C-Spine’s case, the Court of Appeals’ judgment was affirmed on alternate grounds, and the case was remanded to the trial court to consider whether C-Spine could cure the defect. In Wallace’s case, the Court of Appeals’ judgment was affirmed in part, reversed in part, and vacated in part, and the case was remanded for the trial court to consider whether equitable rescission was warranted and whether the real party in interest defect could be cured. View "Wallace v. Smart" on Justia Law

Mark A. Hackel, the Macomb County Executive, filed a lawsuit in 2018 against the Macomb County Board of Commissioners (the Commission) seeking declaratory relief and a writ of mandamus regarding the Commission's authority. The complaint was dismissed, and the dismissal was not appealed. The Commission counterclaimed, seeking declaratory relief and a writ of mandamus to compel Hackel to provide real-time, read-only access to the county’s financial management software, arguing it was necessary for their budgeting duties. Hackel refused the request, despite the Commission including the requirement in annual appropriations ordinances since 2017.The Macomb Circuit Court denied the Commission’s motion for partial summary disposition and granted Hackel’s motion, ruling that the ordinance requiring access unlawfully infringed on Hackel’s authority under the county charter. The court dismissed the remaining claims by stipulation in August 2022. The Commission appealed, and the Michigan Court of Appeals affirmed the circuit court’s decision, holding that the ordinance was invalid as it interfered with the county executive’s control over county departments.The Michigan Supreme Court reviewed the case and held that the Macomb County Charter allows the Commission to require the county executive to provide digital real-time, read-only access to financial information through a validly enacted local ordinance. The Court found that the ordinance did not conflict with other provisions of the county charter or state law and was therefore valid. The Court of Appeals judgment was reversed, and the case was remanded to the circuit court for further proceedings consistent with this opinion. View "Hackel v. Macomb County Board Of Commissioners" on Justia Law

Giorgio Webster sued Dr. Jeffrey Osguthorpe and Summit Oral and Maxillofacial Surgery, PC, for dental malpractice related to a biopsy. On December 8, 2020, a mandatory case evaluation resulted in an award for Webster, which he accepted, but the defendants rejected. The case proceeded to trial after multiple settlement conferences and facilitations. The jury awarded Webster $68,000 in past economic damages and $2.682 million in noneconomic damages, which was later adjusted to $565,000 due to statutory caps. Webster sought costs, statutory interest, and attorney fees as case-evaluation sanctions under the former MCR 2.403(O), which allowed such sanctions before its amendment on January 1, 2022.The Macomb Circuit Court granted Webster's request for sanctions, applying the former rule, and the parties agreed on reasonable attorney fees. The trial court entered an amended judgment reflecting these fees, statutory interest, and costs. The defendants appealed, and the Michigan Court of Appeals reversed the sanctions award, stating that the trial court should not have applied the former rule since the verdict was substantially higher than the case-evaluation award, causing no injustice to Webster.The Michigan Supreme Court reviewed the case and held that the trial court had the discretion to apply the former MCR 2.403(O) under MCR 1.102, which allows a court to apply former rules if applying the current rules would work an injustice. The Supreme Court found that the trial court did not abuse its discretion, as Webster had relied on the former rule when making strategic decisions, and all relevant actions occurred before the rule change. The Court of Appeals' judgment was reversed in part, and the trial court's award of case-evaluation sanctions was reinstated. View "Webster v. Osguthorpe" on Justia Law

The Department of Health and Human Services (DHHS) filed a petition in the Wayne Circuit Court to take jurisdiction over a minor, DVL, from the respondent-mother under MCL 712A.2(b)(1) or (2). DVL, who had a history of mental illness, was taken to St. John Hospital after attempting to start a fire and threatening suicide. The hospital cleared DVL for discharge without treatment, recommending intensive outpatient services. The respondent refused to pick up DVL, citing safety concerns for her other children and herself. The trial court denied the petition, finding no evidence of neglect or abuse by the respondent, who had made numerous efforts to seek help for DVL.The Court of Appeals reversed the trial court's decision in a split unpublished decision, holding that jurisdiction was appropriate under both MCL 712A.2(b)(1) and (2). The majority found that the respondent's actions rendered the home environment dangerous for DVL and her other children, making it statutorily unfit. The respondent sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court, in lieu of granting leave to appeal, held that the trial court did not clearly err by refusing to take jurisdiction of DVL under MCL 712A.2(b)(1) or (2). The Court found that the respondent was not "able" to provide necessary care and support for DVL at home due to the danger he posed to himself and others. Additionally, the respondent's refusal to take DVL home was not considered neglectful, as she acted as a reasonably prudent person would under the circumstances. The Court reversed the Court of Appeals decision and remanded the case to the trial court for reinstatement of its order denying DHHS's petition. View "In Re Lange" on Justia Law

James Stefanski, a former employee of Saginaw County 911 Communications Center Authority, alleged that he was constructively discharged in retaliation for reporting his supervisor's gross negligence. The incident in question involved a 911 call where the supervisor coded the call as "shots fired" instead of "someone shot," resulting in a delayed emergency medical response and the subsequent death of a woman. Stefanski reported his concerns to the director, who dismissed them as a judgment call. Following this, Stefanski experienced increased stress, missed work, and eventually resigned after being suspended for excessive absences, which he believed was a pretext for retaliation.The Saginaw Circuit Court granted summary disposition to the defendant, ruling that reporting gross negligence, a common law violation, was not protected under the Whistleblowers' Protection Act (WPA). The Court of Appeals affirmed this decision, relying on a precedent that reporting common law violations, such as malpractice, does not fall under the WPA's protections.The Michigan Supreme Court reviewed the case and held that the term "law" in the WPA includes the common law. The court reversed the Court of Appeals' decision and remanded the case to determine whether gross negligence is a violation of "a" law under the WPA and whether Stefanski's actions constituted a report under the statute. The Supreme Court emphasized that the WPA should be liberally construed to protect whistleblowers and that excluding common law from its scope would undermine its purpose. View "Stefanski v. Saginaw County 911 Communications Center Authority" on Justia Law

Andrew Czarnecki and Montario Taylor were convicted of first-degree premeditated murder in separate cases. Czarnecki was 19 years old at the time of his crime, while Taylor was 20 years old. Both were sentenced to mandatory life in prison without the possibility of parole (LWOP) as required by Michigan law. They argued that their sentences were unconstitutional under Michigan’s prohibition against cruel or unusual punishment.Czarnecki’s conviction and sentence were affirmed by the Michigan Court of Appeals, which reasoned that the precedent set in People v Hall, which upheld mandatory LWOP for felony murder, remained binding. Taylor’s conviction and sentence were similarly affirmed by the Michigan Court of Appeals, which also relied on Hall and other binding decisions. Both defendants sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court extended its decision in People v Parks, which held that mandatory LWOP for 18-year-olds was unconstitutional, to include individuals who were 19 or 20 years old at the time of their crime. The Court held that mandatory LWOP for 19- and 20-year-olds violates the principle of proportionality and constitutes cruel punishment under the Michigan Constitution. The Court ruled that Czarnecki and Taylor are entitled to individualized sentencing procedures before LWOP can be imposed. The Court reversed the Court of Appeals’ decisions, vacated the defendants’ sentences, and remanded the cases for resentencing in accordance with the new ruling. This decision applies retroactively to cases on collateral review. View "People v. Czarnecki" on Justia Law