Justia Michigan Supreme Court Opinion Summaries

The case concerns an individual who was injured in an automobile accident while driving a car borrowed from a friend without seeking or obtaining permission. The driver did not have a valid license or insurance at the time. After the accident, she applied for personal protection insurance (PIP) benefits through the Michigan Assigned Claims Plan, and her claim was assigned to an insurer, which denied coverage. The insurer argued that her claim was barred under MCL 500.3113(a) because the vehicle was allegedly taken unlawfully and she did not have a reasonable belief that she had permission to use it.The Wayne Circuit Court denied the insurer’s motion for summary disposition and denied reconsideration. On appeal, the Michigan Court of Appeals reversed, concluding that the driver was not entitled to PIP benefits because her lack of a valid driver’s license meant she was unlawfully operating the vehicle at the time of the accident. The appellate court found that, since operating without a license is a criminal offense, this constituted an unlawful taking under the relevant statute.The Supreme Court of Michigan reviewed the decision and held that the appellate court misinterpreted MCL 500.3113(a). The Supreme Court clarified that the statute bars PIP benefits only if the vehicle was “taken unlawfully,” which is distinct from being “operated unlawfully.” The focus should be on how possession of the vehicle was gained, not on unlawful operation, such as driving without a license. The Supreme Court reversed the appellate court’s ruling and remanded the case for further proceedings to consider whether the driver’s actions constituted an unlawful taking of the vehicle, as opposed to unlawful operation. View "Swoope v. Citizens Insurance Co Of The Midwest" on Justia Law

A public school district alleged that, beginning in 2008, another district enrolled students who resided within its boundaries without its approval, in violation of Michigan’s State School Aid Act. Because state funding is allocated based on student enrollment, the plaintiff claimed it was deprived of millions in funding. After an initial lawsuit was dismissed for failure to exhaust administrative remedies, the plaintiff sought relief from the Michigan Department of Education (MDE), which twice declined to issue a declaratory ruling on the matter. The plaintiff then repeatedly returned to court, seeking declaratory relief and asserting unjust enrichment. Each time, the MDE’s refusal to issue a ruling and the plaintiff’s failure to appeal that denial through a petition for review under the Administrative Procedures Act (APA) became the basis for dismissal.The Macomb Circuit Court twice granted summary disposition to the defendant, concluding that the plaintiff was required to exhaust administrative remedies by appealing the MDE’s denial through the APA process. On appeal, the Michigan Court of Appeals ultimately affirmed the trial court, relying on the earlier decision in Human Rights Party v Michigan Corrections Commission, and held that the plaintiff was required to challenge the agency’s refusal through the APA’s petition-for-review procedure, not via an independent action.The Supreme Court of Michigan reversed the judgment of the Court of Appeals. The Supreme Court held that neither MCL 24.263 nor MCL 24.264 required a party to appeal an agency’s decision not to issue a declaratory ruling through the APA petition-for-review process. Instead, after an agency declines to issue a declaratory ruling, the requesting party is free to seek a declaratory judgment in circuit court or pursue any other available remedy. The Court overruled Human Rights Party and related decisions, remanding the case for further proceedings. View "Warren Consolidated School District v. Hazel Park School District" on Justia Law

In this case, the defendant was charged with first-degree premeditated murder and felony-firearm after a circuit judge, acting as a one-person grand jury under Michigan’s statutory scheme, filed a two-count indictment against him. The defendant moved for a preliminary examination or to quash the information, but the trial court denied the motion. A jury later convicted him on both counts. The defendant’s direct appeal and first motion for relief from judgment were unsuccessful. Following the Michigan Supreme Court’s decision in People v Peeler, which held that a defendant charged under the one-person grand jury law is entitled to a preliminary examination and that a judge may not issue a criminal indictment under that law, the defendant filed a second motion for relief from judgment, arguing that Peeler applied retroactively and rendered his indictment—and thus his convictions—void for lack of subject-matter jurisdiction.The Jackson Circuit Court denied the defendant’s second motion, finding Peeler did not apply retroactively and, even if it did, the defendant could not show prejudice because the jury convicted him after a fair trial. The Michigan Court of Appeals affirmed, holding that Peeler did not affect subject-matter jurisdiction, did not announce a new rule of law, and did not apply retroactively on collateral review.Upon review, the Michigan Supreme Court affirmed in part and vacated in part. It held that, although Peeler established a new rule of law by barring one-person grand jury indictments and requiring preliminary examinations, violations of Peeler do not implicate a circuit court’s subject-matter jurisdiction and do not apply retroactively on collateral review. The Court affirmed the denial of relief on alternative grounds but vacated the Court of Appeals’ conclusion that Peeler did not announce a new rule of law. View "People Of Michigan v. Robinson" on Justia Law

The defendant was convicted by a jury in Macomb Circuit Court of first-degree criminal sexual conduct for the sexual assault of his five-year-old daughter. He was originally sentenced to 360 to 550 months in prison, along with lifetime electronic monitoring and lifetime registration under Michigan’s Sex Offenders Registration Act (SORA). After an initial appeal, his sentence was vacated for exceeding the statutory minimum without justification, and upon resentencing, he received 300 to 480 months, with the same monitoring and registration requirements.The Michigan Court of Appeals first affirmed the conviction but vacated the original sentence and remanded for resentencing. On remand, the trial court imposed a new sentence, and the defendant again appealed, arguing that lifetime registration under SORA was cruel or unusual punishment, and that lifetime electronic monitoring was both cruel or unusual and constituted an unreasonable search. The Court of Appeals affirmed the revised sentence and rejected his constitutional challenges.The Michigan Supreme Court reviewed the case, focusing on whether the 2021 SORA, as amended, constituted cruel or unusual punishment under the Michigan Constitution, and whether lifetime electronic monitoring posed constitutional issues. The Supreme Court held that the 2021 SORA does constitute punishment but is not cruel or unusual, either facially or as applied to the defendant. The Court found that the statute’s requirements, although burdensome and excessive in some respects, are not grossly disproportionate to the offense for Tier III offenders. The Supreme Court affirmed the Court of Appeals’ judgment regarding SORA but vacated it to the extent that its reasoning was inconsistent with the Supreme Court’s opinion. The Court denied leave on the defendant’s challenges related to lifetime electronic monitoring. View "People Of Michigan v. Kardasz" on Justia Law

Michael G. Carson was convicted by a jury in the Emmet Circuit Court of multiple charges, including safebreaking, larceny, and conspiracy, after being accused of stealing money and personal property from his neighbor, Don Billings. Billings had allowed Carson and his girlfriend, Brandie DeGroff, access to his house to help sell items online, but later discovered that valuable items and cash were missing. Carson was arrested, and his cell phone was seized and searched, revealing incriminating text messages. Carson's defense counsel moved to suppress these messages, arguing the seizure of the phone without a warrant violated the Fourth Amendment, but the motion was denied.Carson was sentenced to various prison terms for each conviction. He appealed, claiming ineffective assistance of counsel for not challenging the search warrant's adequacy. The Court of Appeals reversed his convictions, ruling the search warrant was too broad and the good-faith exception did not apply. They also found trial counsel ineffective for not seeking exclusion of the phone's contents based on the warrant's broadness. The prosecution appealed to the Michigan Supreme Court.The Michigan Supreme Court held that the search warrant was insufficiently particular under the Fourth Amendment, as it allowed a general search of the phone's contents without meaningful limitations. However, the Court disagreed with the Court of Appeals on the ineffective assistance of counsel claim, concluding that Carson's counsel's performance was not constitutionally deficient given the evolving nature of Fourth Amendment law regarding digital data. The Court reversed the Court of Appeals' judgment on this point and remanded the case for consideration of Carson's remaining issues. View "People Of Michigan v. Carson" on Justia Law

The Department of Health and Human Services (DHHS) petitioned the Lenawee Circuit Court, Family Division, to take jurisdiction over two minor children, CB and ME, and terminate the parental rights of their mother after CB alleged sexual abuse by two of the mother's male friends. CB claimed the mother was aware of the abuse and allowed it in exchange for drugs. The court authorized the petition, suspended the mother's parenting time, and ordered the children to remain with their father. At the combined adjudication and termination hearing, CB testified about the abuse, and the court found her testimony credible, concluding that grounds for adjudication and termination existed.The trial court terminated the mother's parental rights under MCL 712A.19b(3)(b)(i), (b)(ii), and (j), finding that termination was in the children's best interests. The mother appealed, and the Michigan Court of Appeals reversed and remanded, concluding that aggravated circumstances were not present under MCL 722.638(1)(a)(ii) because the mother was not the perpetrator of the criminal sexual conduct. The court also found that the trial court erred by not advising the mother of her right to appeal the removal order.The Michigan Supreme Court reviewed the case and held that under MCL 712A.19a(2)(a), DHHS is not required to make reasonable efforts to reunify the family when there is a judicial determination of aggravated circumstances as provided in MCL 722.638(1) and (2). The court concluded that the mother subjected CB to aggravated circumstances by facilitating criminal sexual conduct involving penetration, even though she did not personally commit the act. The court also found that the trial court's failure to advise the mother of her right to appeal the removal order was plain error but did not affect her substantial rights. The Supreme Court reversed the Court of Appeals' judgment and reinstated the trial court's order terminating the mother's parental rights. View "In Re Barber/Espinoza Minors" on Justia Law

A certified nursing assistant was hired by a nursing care facility in February 2017. A week into her employment, she signed an acknowledgment that included a 180-day limitations period for bringing any employment-related claims. She reported inappropriate behavior by upper management and alleged retaliation by her manager. She was terminated in July 2017 and filed a complaint in April 2020, alleging various claims including violations of the Elliott-Larsen Civil Rights Act (ELCRA).The Macomb Circuit Court granted the defendant's motion for summary disposition, dismissing the plaintiff's claims based on the 180-day limitations period in the acknowledgment. The plaintiff appealed, arguing that the shortened limitations period was unconscionable. The Court of Appeals affirmed the lower court's decision, relying on precedent that upheld such limitations periods in employment contracts.The Michigan Supreme Court reviewed the case, focusing on whether the contractual limitations period was enforceable. The Court held that while contractually shortened limitations periods are generally permitted, they require close judicial scrutiny when included in non-negotiated, adhesive employment agreements. The Court overruled previous decisions that did not apply this scrutiny and reinstated the framework from Camelot Excavating Co. and Herweyer v. Clark Hwy Servs., which require a reasonableness analysis for such limitations periods.The Court concluded that the 180-day limitations period in the plaintiff's employment agreement was adhesive and warranted close judicial scrutiny. The case was remanded to the Macomb Circuit Court to develop a full record and determine the reasonableness of the shortened limitations period and whether it was unconscionable. If found unreasonable or unconscionable, the statutory three-year limitations period would apply. View "Rayford v. American House Roseville I LLC" on Justia Law

An assistant prosecuting attorney, Jennifer Janetsky, filed a lawsuit against Saginaw County, the Saginaw County Prosecutor’s Office, John McColgan, and Christopher Boyd. Janetsky alleged violations of the Whistleblowers’ Protection Act (WPA), public policy violations, assault and battery, intentional infliction of emotional distress, and false imprisonment. The case stemmed from Janetsky’s handling of a criminal sexual conduct prosecution and subsequent alleged retaliatory actions by her supervisors, McColgan and Boyd, after she reported concerns about a plea agreement.The Saginaw Circuit Court granted summary disposition to the Saginaw County Prosecutor’s Office on all claims, to all defendants on the intentional infliction of emotional distress claim, and to McColgan on the intentional-tort claims, but denied the motion for the remaining claims. The Court of Appeals reversed the trial court’s judgment in part, ordering summary disposition in favor of all defendants on the remaining claims. The Michigan Supreme Court reversed in part and remanded to the Court of Appeals to consider unresolved issues. On remand, the Court of Appeals again reversed in part, ordering summary disposition on the intentional-tort and public-policy claims in favor of all defendants and on the WPA claim in favor of Saginaw County.The Michigan Supreme Court held that the Court of Appeals erred in reversing the trial court’s denial of summary disposition. The Supreme Court determined that Saginaw County was an employer under the WPA, allowing Janetsky to sue under the Act. The Court also established a test for wrongful termination in violation of public policy, remanding the case to the trial court to apply this test. Additionally, the Court found genuine issues of material fact regarding Janetsky’s intentional-tort claims, including false imprisonment and assault and battery, sufficient to defeat summary disposition. The judgment of the Court of Appeals was reversed in part, and the case was remanded for further proceedings. View "Janetsky v. County Of Saginaw" on Justia Law

Jacqueline Davis filed a lawsuit against BetMGM, LLC, in the Wayne Circuit Court, claiming fraud, conversion, and breach of contract after winning over $3 million on BetMGM's online gambling platform. BetMGM approved her withdrawal of $100,000 but later suspended her account, citing a game malfunction that erroneously credited her winnings. BetMGM refused to remit the remaining winnings, leading Davis to file a complaint with the Michigan Gaming Control Board (MGCB) and subsequently in court.The Wayne Circuit Court granted BetMGM's motion for summary disposition, ruling that the Lawful Internet Gaming Act (LIGA) preempted Davis's claims and that the MGCB had exclusive jurisdiction over online gambling disputes. The court relied on caselaw interpreting the Michigan Gaming Control and Revenue Act (MGCRA) and administrative rules under the LIGA, concluding that the LIGA precluded inconsistent common-law claims. Davis's motion for reconsideration was denied.The Michigan Court of Appeals affirmed the circuit court's decision in a split decision. The majority agreed with the lower court's reasoning, while the dissent argued that the MGCB did not have the authority to resolve individual patron disputes and that Davis's claims were not inconsistent with the LIGA. The dissent also noted that the MGCB's role was limited to investigating violations of the LIGA and did not extend to adjudicating disputes between patrons and licensees.The Michigan Supreme Court reversed the Court of Appeals' decision, holding that the LIGA did not abrogate common-law claims of fraud, conversion, and breach of contract. The court clarified that the correct principle to apply was abrogation, not preemption, and found no clear legislative intent to abrogate these common-law claims. The court also determined that Davis's claims were not inconsistent with the LIGA, as the MGCB did not have the authority to resolve such disputes. The case was remanded to the circuit court for further proceedings. View "Davis v. BetMGM, LLC" on Justia Law

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