Justia Michigan Supreme Court Opinion Summaries

The case arose from a dispute over property ownership following the death of a homeowner who did not leave a will. The defendant, who had lived in the home with his children and grandmother, refused to leave after her death despite an eviction order. When sheriff’s deputies arrived to enforce the eviction, the defendant resisted leaving and was arrested. As a result, he was charged with trespassing and two counts of resisting or obstructing a police officer. The defendant maintained throughout that he believed he had a right to remain in the home and thus was not trespassing.After a jury trial in Emmet Circuit Court, the defendant was convicted on all counts. He moved for a new trial, arguing that his Sixth Amendment rights were violated when his counsel conceded guilt on the trespassing charge during closing argument without consulting him or securing his consent. At the evidentiary hearing, trial counsel testified that the defendant had consistently maintained his innocence before trial and was not informed of the plan to concede guilt. The trial court denied the motion, reasoning that the defendant failed to cooperate with counsel and did not object to the concession. The Court of Appeals affirmed, finding that counsel acted within his discretion given the lack of communication.The Michigan Supreme Court reviewed the case and held that under McCoy v. Louisiana, a criminal defendant has the right to decide the objective of the defense, including maintaining innocence. The Court found that defense counsel’s unilateral concession of guilt, despite the defendant’s insistence on innocence and without consultation, violated this right. The Court clarified that a defendant is not required to contemporaneously object to preserve this claim. The structural error required automatic reversal. The judgment of the Court of Appeals was reversed, the convictions vacated, and the case remanded for a new trial on all charges. View "People Of Michigan v. Klungle" on Justia Law

A woman pleaded guilty to third-degree retail fraud after stealing clothing from a store and was sentenced in the 64B District Court to probation under the Holmes Youthful Trainee Act. As a condition of probation, she was prohibited from using or possessing marijuana, although the court provided no specific justification for this restriction. During probation, she tested positive for marijuana twice, leading to probation violation charges. She then moved to amend her probation to permit marijuana use consistent with the Michigan Regulation and Taxation of Marihuana Act (MRTMA) and to vacate or dismiss her probation violations, arguing that the MRTMA protected such use.The district court denied her motion, found her in violation, revoked her youthful trainee status, and sentenced her to jail. On appeal, the Montcalm Circuit Court stayed her jail sentence but otherwise affirmed the lower court's decisions. The Michigan Court of Appeals also affirmed, reasoning that the probation act prohibits probationers from violating federal law, and since federal law criminalizes recreational marijuana, the act allowed—if not required—courts to prohibit MRTMA-compliant marijuana use as a probation condition.The Michigan Supreme Court reviewed the case and reversed the Court of Appeals. The Supreme Court held that a trial court may not prohibit MRTMA-compliant marijuana use as a probation condition solely because such use violates federal law. The Court explained that federal law does not preempt the MRTMA and that to the extent the probation act incorporates federal marijuana prohibitions, it is inconsistent with the MRTMA and does not apply to conduct permitted by the MRTMA. The Supreme Court remanded the case for the trial court to reconsider the defendant’s motions in light of this holding. View "People Of Michigan v. Hess" on Justia Law

A woman died from a pulmonary embolism roughly 30 days after undergoing knee replacement surgery. Her estate, through its personal representative, filed a medical malpractice suit in the Oakland Circuit Court against the operating surgeon, his orthopedic practice, and the hospital where the surgery occurred. The estate alleged that the surgeon negligently failed to prescribe a prescription-strength anticoagulant. The complaint was accompanied by an affidavit of merit from an orthopedic surgeon, attesting to his qualifications during the relevant time period. The estate timely identified this surgeon as its expert witness, but difficulty arose when he became unavailable for deposition. The estate attempted to substitute a new expert on its witness list without seeking court approval, prompting litigation over whether this substitution should be permitted.The Oakland Circuit Court struck the amended witness list and ordered the estate to produce the original expert for deposition. When the estate could not do so, it sought to amend its witness list and moved for voluntary dismissal, both of which the circuit court denied. The court found that the estate had not acted diligently, determined the affidavit of merit was invalid due to the expert’s lack of recent practice, and granted summary disposition in favor of the defendants, closing the case.The Michigan Court of Appeals held that the circuit court abused its discretion by considering only prejudice when denying the motion to amend the witness list and failing to apply the factors from Dean v Tucker. Upon review, the Michigan Supreme Court reversed in part, holding that the correct standard for amending a witness list is the “good-cause” standard of MCR 2.401(I)(2), not the Dean factors. The Supreme Court found that the circuit court abused its discretion under the good-cause standard and that summary disposition was prematurely granted. The case was remanded to the circuit court for further proceedings. View "Estate Of Harris v. Beaumont Health" on Justia Law

The case concerns a fatal collision between a car driven by the defendant and a motorcycle operated by the decedent. The incident occurred in Brighton Township, Michigan, when the decedent, after accelerating rapidly from a traffic light, struck the side of the defendant’s vehicle as the defendant attempted a U-turn. Eyewitness testimony suggested the decedent may have been speeding, potentially exceeding the speed limit by up to 20 miles per hour. Post-mortem toxicology indicated the decedent’s blood alcohol concentration (BAC) could have been between 0.071 and 0.081 g/dL at the time of the collision. The defendant sought to admit evidence of both the decedent’s speed and BAC as relevant to proximate cause and gross negligence.The 53rd District Court admitted evidence regarding the decedent’s speed but excluded the BAC evidence, deeming it irrelevant. The Livingston Circuit Court denied the defendant’s application for leave to appeal this exclusion. The Michigan Court of Appeals, in a split decision, affirmed the district court’s ruling, finding that People v Feezel required a preliminary showing of gross negligence before evidence of intoxication could be admitted and that no such showing was made in this case. The dissent argued for considering all conduct, including intoxication and speeding, together rather than in isolation.The Supreme Court of Michigan reviewed the case and reversed the Court of Appeals. The Court held that the district court abused its discretion by excluding the BAC evidence. Under People v Feezel, BAC evidence is relevant if it has any tendency to make gross negligence more or less probable. The Supreme Court found that, given the admissible evidence of speeding and acceleration, the BAC evidence was relevant to proximate causation and not unfairly prejudicial. The judgment of the Court of Appeals was reversed, the district court’s order vacated, and the case remanded for further proceedings. View "People Of Mi v. Morgan" on Justia Law

In this case, a homeowner experienced property damage when sewage backed up into his residence after a sewer line was damaged during nearby excavation work. The excavation was initiated by a utility company, which hired an excavator to install a new underground electrical line following a neighbor’s complaint about electrical service. Before the excavation, the excavator notified MISS DIG Systems as required by law, which then informed local facility owners, including the township. The township responded that it did not have any facilities in the area and did not mark any sewer lines. The homeowner alleged that the township failed to comply with its duty under the MISS DIG Underground Facility Damage Prevention and Safety Act by not marking a township-owned sewer line, leading to his damages.The Oakland Circuit Court denied the township’s motion for summary disposition, concluding that governmental immunity did not shield the township from liability because the MISS DIG Act created an exception. The court also granted the homeowner leave to amend his complaint to assert a claim under the sewage disposal system event (SDSE) exception to governmental immunity, and set aside the notice issue for further briefing. The Michigan Court of Appeals affirmed the trial court’s decision.Upon review, the Michigan Supreme Court held that a governmental agency cannot be held civilly liable for monetary damages for a violation of the MISS DIG Act in circuit court, as the statute provides that the exclusive remedy is to file a complaint with the Public Service Commission. The Court also found that the trial court erred in granting the homeowner leave to amend his complaint to assert the SDSE exception before he demonstrated compliance with the statutory notice requirement. The Supreme Court reversed the decisions of the lower courts on these issues, vacated the grant of leave to amend, and remanded for further proceedings. View "Zezula v. Brown" on Justia Law

A state agency responsible for Medicaid administration alleged that a pharmacy and its owner, operating as a Medicaid provider, received excess Medicaid payments between 2011 and 2016 by submitting claims for more medications than records supported. After an audit, an administrative law judge upheld the agency’s determination of overpayment. The agency issued a final order demanding repayment, which survived several unsuccessful challenges by the pharmacy. In 2022, the agency, represented by the Attorney General, filed a civil action in Ingham County seeking to enforce its order and alleging common-law and statutory conversion, breach of contract, and unjust enrichment related to the overpayments.The defendants moved to change venue, arguing that the action should be heard in Wayne County, where the pharmacy owner resided and where the acts giving rise to the claims allegedly occurred, based on Michigan’s tort venue statutes. The Ingham Circuit Court transferred the case to Oakland County, identifying it as the site of the original injury. The Michigan Court of Appeals affirmed, holding that the tort venue statutes took precedence over the Attorney General venue provisions and that venue was proper in Oakland County, where the pharmacy’s registered office was located and where the funds were allegedly wrongfully withheld.The Supreme Court of Michigan reviewed the case and agreed with the Court of Appeals that the tort venue statutes, specifically MCL 600.1629 as mandated by MCL 600.1641(2), governed the venue determination because the complaint contained multiple claims, including a tort. However, the Supreme Court held that the “original injury” occurred in Ingham County, where the state agency was deprived of the funds and conducts its business. Therefore, venue was proper in Ingham County, not Oakland County. The Court affirmed in part, reversed in part, and remanded for transfer of the case to the Ingham Circuit Court. View "Department Of Health And Human Services v. Nrk Rx Inc." on Justia Law

In 2004, the defendant was sentenced as a juvenile for three counts of third-degree criminal sexual conduct and became subject to Michigan’s Sex Offenders Registration Act (SORA), which at the time required reporting address changes within ten days. In 2010, the defendant was convicted for failing to comply with SORA’s registration requirements. After SORA was amended in 2011 to require address changes to be reported within three business days, the defendant’s address was incorrect for 19 days due to an aborted move. In 2015, he pleaded guilty to failure to comply with the 2011 SORA’s requirements and, as a fourth-offense habitual offender, received six months in jail and five years’ probation. After a probation violation, he was resentenced to 40 months to 15 years in prison.After the Michigan Supreme Court decided People v Betts in 2021—holding that the 2011 SORA was unconstitutional ex post facto punishment when applied to offenses committed before 2011—the defendant moved in Tuscola County Circuit Court to vacate his 2015 conviction. The trial court granted relief without allowing the prosecution to respond. The prosecution’s motion for reconsideration was denied. The Michigan Court of Appeals reversed, holding that Betts did not apply retroactively and that the trial court erred by not affording the prosecution an opportunity to respond, and remanded for reinstatement of the conviction.The Michigan Supreme Court reviewed the case and held that its decision in Betts applies retroactively to defendants on collateral review under both federal and state constitutional law. The Court reasoned that Betts announced a new substantive rule by prohibiting a category of punishment for a class of defendants based on their offense date, and such substantive rules are retroactively applicable. The Michigan Supreme Court reversed the Court of Appeals and remanded for further proceedings. View "People Of Mi v. Shaver" on Justia Law

The plaintiff purchased an auto insurance policy covering two vehicles, providing information about her address, where the vehicles were typically garaged, and who resided with her. After being injured as a passenger in an accident involving an unidentified driver, the plaintiff sought personal protection insurance benefits from her insurer. The insurer investigated and discovered that the plaintiff had not accurately disclosed the garaging location of the vehicles and the presence of other resident-relatives in her household. These misstatements would have resulted in a significantly higher insurance premium had they been truthfully reported. As a result, the insurer rescinded the policy from its inception and refunded all premium payments to the plaintiff.The plaintiff then filed suit in the Washtenaw Circuit Court, arguing that the insurer had unlawfully denied her benefits and breached the contract. The insurer moved for summary disposition, asserting the policy was void due to material misrepresentations. The trial court denied this motion and instead ordered reformation of the policy to reflect the correct address and an increased premium, requiring the plaintiff to repay the difference. The insurer appealed. The Michigan Court of Appeals reversed the trial court’s order, finding that the plaintiff’s misrepresentations were material and that the equities favored rescission, not reformation. The plaintiff’s motion for reconsideration was granted as to clarifying the applicable standard of review but the appellate court again ruled for the insurer.Upon further appeal, the Michigan Supreme Court affirmed the Court of Appeals. It clarified that appellate courts should review the trial court's grant or denial of rescission for abuse of discretion, not de novo, after first ensuring there is no genuine issue of material fact. The Court held that rescission was the proper remedy given the plaintiff’s material misrepresentations and the absence of any wrongdoing by the insurer, and that the trial court had abused its discretion in ordering reformation. View "Sherman v. Progressive Michigan Insurance Company" on Justia Law

An elderly man, Jerome, experienced significant health decline and was moved into a nursing home, prompting his wife, Janet, to petition the Saginaw Probate Court for a protective order under Michigan law. She requested the transfer of all of Jerome’s assets and most of his income to her, citing her increased financial needs and Jerome’s inability to manage his affairs due to physical and mental health issues. Janet’s petition was filed before Jerome’s application for Medicaid was resolved, and the probate court granted the transfer and set a monthly support payment for Janet.The Department of Health and Human Services (DHHS) appealed. The Michigan Court of Appeals affirmed in part but vacated the probate court’s order, relying on its earlier precedent in In re Estate of Schroeder, which prohibited consideration of Medicaid eligibility before a formal determination. The case was remanded for a new assessment of need and current valuation of assets. On remand, the probate court again ordered the transfer and support, applied retroactively, but the Court of Appeals vacated this order as well, citing reliance on outdated asset information and the same legal standard regarding Medicaid eligibility.The Michigan Supreme Court reviewed the case after Jerome’s death, holding that the appeal was not moot because Medicaid benefits can be awarded retroactively, even to a deceased individual’s estate. The Supreme Court ruled that probate courts may consider the likely availability of Medicaid benefits before a final eligibility determination when assessing the needs of an individual and their dependents under MCL 700.5401(3)(b). The Court expressly overruled the contrary rule announced in In re Estate of Schroeder, reinstated the probate court’s 2022 protective order, and remanded the case for further proceedings. View "In Re Estate Of Sizick" on Justia Law

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