Justia Michigan Supreme Court Opinion Summaries

Helen Jordan, a nurse who was formerly employed by the predecessor to the Michigan Department of Health and Human Services, challenged in the Michigan Compensation Appellate Commission (MCAC) the decision of a magistrate that she was not entitled to disability benefits under the Worker’s Disability Compensation Act (WDCA). In 1995, plaintiff was working for defendant’s predecessor when she was injured during an altercation with a patient. Plaintiff was prescribed opioid medication to treat leg and back pain that she said resulted from the 1995 injury, and she used the opioid medication continuously after the incident and became dependent upon it. Plaintiff began receiving disability benefits under the WDCA in 1996. In 2015, plaintiff underwent an independent medical examination at defendant’s request pursuant to MCL 418.385. The doctor who conducted the examination concluded that any disability experienced by plaintiff was not the result of the 1995 incident, and defendant subsequently discontinued plaintiff’s benefits. Plaintiff applied for reinstatement of her benefits under the WDCA. The Michigan Supreme Court determined the agency record was too incomplete to facilitate “meaningful” appellate review: “Despite the MCAC’s conclusion, whether the experts agreed that plaintiff had a limitation of her wage-earning capacity in work suitable to her qualifications and training was not clear from the record.” Therefore, the Court concluded the Court of Appeals erred by deciding this case as a matter of law because further administrative proceedings were needed. View "Jordan v. Dep’t. of Health & Human Servs." on Justia Law

Rouch World, LLC, and Uprooted Electrolysis, LLC, brought an action before the Michigan Court of Claims against the Department of Civil Rights and its director, seeking, among other relief, a declaratory judgment that the prohibition of sex discrimination in places of public accommodation under the Elliott-Larsen Civil Rights Act (ELCRA) did not bar discrimination based on sexual orientation or gender identity. The owners of Rouch World had denied a request to host the same-sex wedding of Natalie Johnson and Megan Oswalt at their facility, claiming that doing so would violate their religious beliefs. The owner of Uprooted Electrolysis had denied hair-removal services to Marissa Wolfe, a transgender woman, on the same basis. Johnson, Oswald, and Wolfe filed complaints with the Department of Civil Rights, which had issued an interpretive statement in 2018 indicating that the ELCRA’s prohibition against discrimination based on sex included sexual orientation and gender identity. The Department of Civil Rights opened an investigation into both of these incidents, but the investigations were stayed when plaintiffs brought this action. The Michigan Supreme Court held that the ELCRA encompasses discrimination on the basis of sexual orientation. The Court overruled the Court of Appeals decision in Barbour v. Dept. of Social Servs, 497 NW2d 216 (1993), and reversed in part the Court of Claims decision below. View "Rouch World LLC v. Department Of Civil Rights" on Justia Law

Grant Bauserman, Karl Williams, and Teddy Broe, on behalf of themselves and all others similarly situated, brought a putative class action in the Michigan Court of Claims against the Unemployment Insurance Agency, alleging that the Agency violated their due-process rights, and that the Agency also engaged in unlawful collection practices. Plaintiffs, who were all recipients of unemployment compensation benefits, specifically alleged defendant had used an automated fraud-detection system, the Michigan Integrated Data Automated System (MiDAS), to determine that plaintiffs had received unemployment benefits for which they were not eligible and then garnished plaintiffs’ wages and tax refunds to recover the amount of the alleged overpayments, interest, and penalties that defendant had assessed without providing meaningful notice or an opportunity to be heard. Among other remedies for this constitutional violation, plaintiffs sought monetary damages. Although the Michigan Supreme Court had never specifically held that monetary damages were available to remedy constitutional torts, the Court now held that they were. “Inherent in the judiciary’s power is the ability to recognize remedies, including monetary damages, to compensate those aggrieved by the state, whether pursuant to an official policy or not, for violating the Michigan Constitution unless the Constitution has specifically delegated enforcement of the constitutional right at issue to the Legislature or the Legislature has enacted an adequate remedy for the constitutional violation. Because enforcement of Const 1963, art 1, § 17 has not been delegated to the Legislature and because no other adequate remedy exists to redress the alleged violations of plaintiffs’ rights, we agree that plaintiffs have alleged a cognizable constitutional-tort claim for which they may recover money damages and we agree with the lower courts that defendant was properly denied summary disposition.” View "Bauserman v. Unemployment Insurance Agency" on Justia Law

Appellant Saugatuck Dunes Coastal Alliance, argued that lower courts erred when they found that the Michigan Zoning Enabling Act (MZEA) denied it standing to appeal the decisions of the Saugatuck Township Planning Commission (Commission). Prior Court of Appeals decisions relied on by the Saugatuck Township Zoning Board of Appeals (ZBA) and lower courts repeatedly and erroneously read the term “party aggrieved” too narrowly. The Michigan Supreme Court held that the MZEA did not require an appealing party to own real property and to demonstrate special damages only by comparison to other real-property owners similarly situated. The Supreme Court overruled several Court of Appeals decisions to the limited extent that they required: (1) real-property ownership as a prerequisite to being “aggrieved” by a zoning decision under the MZEA; and (2) special damages to be shown only by comparison to other real-property owners similarly situated. The Supreme Court explained, to be a “party aggrieved” under MCL 125.3605 and MCL 125.3606, the appellant must meet three criteria: (1) the appellant must have participated in the challenged proceedings by taking a position on the contested proposal or decision; (2) the appellant must claim some protected interest or protected personal, pecuniary, or property right that will be or is likely to be affected by the challenged decision; and (3) the appellant must provide some evidence of special damages arising from the challenged decision in the form of an actual or likely injury to or burden on their asserted interest or right that is different in kind or more significant in degree than the effects on others in the local community. A portion of the Court of Appeals' judgment was vacated, and the case was remanded back to the circuit court for reconsideration in light of the Supreme Court's holding here. View "Saugatuck Dunes Coastal Alliance v. Saugatuck Twp." on Justia Law

Norman Champine brought an action against the Michigan Department of Transportation in the Court of Claims alleging that defendant had breached its duty to maintain I-696. Plaintiff was driving on I-696 in Macomb County when a large piece of concrete dislodged from the road and crashed through the windshield of his car, causing serious injuries. The Court of Claims granted summary judgment in favor of defendant on the basis that plaintiff had failed to provide proper notice under MCL 691.1404. The court reasoned that plaintiff’s separate notice to defendant was inadequate because it was not filed in the Court of Claims, the complaint itself could not serve as notice, and the complaint had not identified the exact location of the highway defect. Plaintiff appealed, and the Court of Appeals affirmed in an unpublished per curiam opinion, holding that the filing of a complaint could not satisfy the statutory notice requirements. The Court of Appeals declined to address whether plaintiff also failed to adequately describe the location of the incident, even assuming plaintiff’s complaint could serve as proper notice. The Michigan Supreme Court determined “notice” was not defined by MCL 691.1404, so courts were permitted to consider its plain meaning as well as its placement and purpose in the statutory scheme. "The plain meaning of the word 'notice' in the context of the statute indicates only that the governmental agency must be made aware of the injury and the defect. The statute does not require advance notice beyond the filing of the complaint, and the Court of Appeals erred by holding otherwise. Plaintiff properly gave notice by timely filing his complaint in the Court of Claims." Nonetheless, the case had to be remanded to the Court of Appeals for that Court to address whether the complaint adequately specified the exact location and nature of the defect as required by MCL 691.1404(1). View "Champine v. Department of Transportation" on Justia Law

David Sole brought an action against the Michigan Economic Development Corporation under the Michigan Freedom of Information Act (FOIA), seeking the disclosure of information regarding the tax credits that defendant had allowed General Motors LLC (GM) to claim under the Michigan Economic Growth Authority Act (the MEGA Act), which gave defendant the authority to award businesses tax credits through the Michigan Strategic Fund. Defendant had provided plaintiff with a 2016 agreement between GM and defendant regarding the tax credits, but it had redacted the amount of the “tax credit cap,” which defendant claimed was exempt from disclosure under the Michigan Strategic Fund Act. The Court of Claims granted summary judgment in favor of defendant on the basis that the information was exempt from disclosure under MCL 125.2005(9). The Court of Appeals affirmed. The Michigan Supreme Court found that while the “tax credit cap” fit within the terms of MCL 125.2005(9), it was nonetheless subject to disclosure under MCL 125.2005(11). Accordingly, the Court reversed the Court of Appeals’ judgment to the contrary. View "Sole v. Michigan Economic Development Corp." on Justia Law

James Township, Michigan filed a nuisance action against Daniel Rice , alleging Rice violated the township’s blight ordinance as well as the Michigan Residential Code by having junk cars, unpermitted construction, and fences of an improper height on his property. Rice moved to dismiss the portions of the citation related to the improper height of his fence and the unpermitted construction, arguing that, under the Right to Farm Act (RTFA), the township was prohibited from enforcing against farms or farm operations local ordinances governing those structures. The township opposed the motion, arguing that the property was not protected by the RTFA because it had not previously been used for farming. Following a hearing, the district court, found that Rice’s use of the property constituted a “farm” or “farm operation” for purposes of the RTFA and that the RTFA was an affirmative defense to those portions of the civil citation. The district court dismissed the specified portions of the citation and denied the parties’ individual requests for costs and fees. Rice moved for reconsideration, arguing that, under MCL 286.473b, he was entitled to costs and expenses, as well as reasonable and actual attorney fees; the district court denied the motion. The district court later dismissed the remaining portions of the citation and dismissed the action with prejudice. Rice appealed and the circuit court affirmed the district court’s order. The Court of Appeals denied Rice’s application for leave to appeal the circuit court’s order. In lieu of granting leave to appeal, the Michigan Supreme Court remanded the case to the Court of Appeals for consideration as on leave granted. On remand, in an unpublished per curiam opinion, the Court of Appeals affirmed the circuit court’s legal conclusions, holding that an award of costs , expenses, and fees was not mandatory under MCL 286.473b, but the Court of Appeals remanded the case to the district court for articulation of the district court’s reasons for the discretionary denial. The Michigan Supreme Court found no such discretion under the RTFA, and Rice was entitled to his fees. The appellate court’s judgment was reversed. View "Township of James v. Rice" on Justia Law

Comerica, Inc. sought to redeem certain tax credits over the Michigan Department of Treasury’s objection. The credits were earned under the Single Business Tax Act by a Comerica affiliate. That subsidiary assigned the credits to another subsidiary, a Michigan bank. Later, Comerica created a third subsidiary, a Texas bank, and merged the Michigan bank into the Texas bank. Comerica then claimed the tax credits, on behalf of the Texas bank, in its Michigan tax filings. The Department of Treasury disallowed the tax credits, concluding that the Texas bank did not receive the Michigan bank’s credits through the merger because the Michigan bank lacked the legal authority to transfer the credits. The Michigan Supreme Court held that the tax credits could lawfully pass to the Texas bank. View "Comerica Inc. v. Department Of Treasury" on Justia Law

Petitioner Andrew Campbell was a lifelong Michigan resident. For many years, petitioner claimed and enjoyed a principal residence exemption (PRE) on his Michigan residence. In late 2016, petitioner purchased a second home in Surprise, Arizona. Respondent Michigan Department of Treasury (Treasury), reviewed and denied petitioner’s PRE claim for his Michigan property for the 2017 tax year. In the ensuing dispute, the issue this case presented for the Michigan Supreme Court's review was whether a property owner was entitled to claim a PRE under Michigan tax law when the owner received a similar tax benefit for a home in another state. To this the Supreme Court concluded that petitioner was not entitled to the PRE. Specifically, under MCL 211.7cc(3)(a), a property owner “is not entitled to [the PRE] in any calendar year in which . . . [t]hat person has claimed a substantially similar exemption, deduction, or credit, regardless of amount, on property in another state.” Accordingly, the Court reversed the judgment of the Court of Appeals and reinstated the Department of Treasury’s October 2, 2018 decision and order of determination denying petitioner’s PRE for the 2017 tax year. View "Campbell v. Department Of Treasury" on Justia Law

The American Civil Liberties Union of Michigan (the ACLU) filed a complaint against the Calhoun County Jail and Calhoun County Sheriff’s Office (the CCSO), alleging CCSO violated Michigan’s Freedom of Information Act (FOIA) when it denied the ACLU’s request for documents. The ACLU sought disclosure of all records related to the December 2018 detention of United States citizen Jilmar Benigno Ramos-Gomez. Ramos-Gomez’s three-day detention at the Calhoun County Correctional Facility occurred pursuant to an Intergovernmental Service Agreement executed between United States Immigration and Customs Enforcement (ICE) and the jail. The CCSO denied the ACLU’s request, asserting that the requested records were exempt from disclosure under MCL 15.243(1)(d) because they related to an ICE detainee. The Court of Appeals affirmed dismissal, finding the records at issue were exempt public records from disclosure under the statute. The Michigan Supreme Court reversed the appellate court, finding error in that court holding a federal regulation had the legal force of a federal statute; "federal regulation is not a federal statute." The case was remanded to the circuit court for further proceedings. View "American Civil Liberties Union of Michigan v. Calhoun County" on Justia Law