Justia Michigan Supreme Court Opinion Summaries

A jury convicted Defendant-Appellant Drew Peltola on drug possession charges. The trial court considered Defendant's prior criminal history ("prior record variables" or PRVs), and calculated his sentence to be in the five to twenty-three month range, with a statutory minimum at twenty years. Because defendant had a prior conviction for a controlled substance, the trial court applied a sentence enhancement. As a result, the court doubled both the minimum and maximum sentences for each conviction and sentenced defendant within the enhanced guidelines range to concurrent terms of 4 to 40 years' imprisonment. Defendant unsuccessfully appealed the trial court's scoring of his PRVs. The question before the Supreme Court involved whether the trial court miscalculated Defendant's sentence based on its scoring of the PRVs. Upon consideration of the trial record and the applicable legal authority, the Supreme Court found that the trial court's enhancing of Defendant's sentence range was authorized by Michigan law. Accordingly, the Court affirmed the trial court's decision and Defendant's sentence. View "Michigan v. Peltola" on Justia Law

Plaintiff Richard Loweke was an employee of an electrical subcontractor. Defendant Ann Arbor Ceiling & Partition Company was also a subcontractor. Both parties were hired for work on a construction project at the Detroit Metro Airport. Plaintiff was injured at the site when several cement boards fell on him. Defendant's employees placed the boards against the wall. Plaintiff sued Defendant for negligence. Defendant moved for summary judgment, arguing that it owed Plaintiff no duty that was "separate and distinct" from the contractual duties it owed to the general contractor. The trial court granted Defendant's motion, and the appellate court affirmed the trial court. On appeal to the Supreme Court, Plaintiff argued that Defendant had a common-law duty to avoid physical harm to others from its own actions. Upon consideration of the parties' briefs and the applicable legal authority, the Supreme Court reversed the lower courts' decisions. The Court found that the trial and appeals courts misinterpreted Michigan law with respect to "duty." The Court held that the assumption of contractual obligations does not limit the common law tort duties owed to others in the performance of the contract. The Court remanded the case to the trial court for further proceedings. View "Loweke v. Ann Arbor Ceiling & Partition, Co., LLC" on Justia Law

The dispute in this case stemmed from a disagreement between Plaintiff Florence Beach and Defendant Lima Township over property rights to an area of land that were shown as streets on the recorded township plat. The land was originally recorded in 1835, and through a series of conveyances, was acquired and held by the Beach family ever since. In 2004, the Township purchased several blocks to build a fire department substation and intended to use the platted streets. Plaintiff disputed the Township's right to use the streets and filed an action to quiet title to them based on adverse possession. The circuit court denied the Township's motion after an evidentiary hearing. The court found that 100-year-old trees were growing in the middle of the "streets," and that the Beach family had adversely possessed them by farming as well as maintaining private trials and fences. On appeal to the Supreme Court, the Township argued that Plaintiff was required to file a claim under the state Land Division Act (LDA) instead of bringing a quiet title action when the property in dispute is on a recorded plat. The Court found that the LDA only applied to cases when a party's interest arose from the platting process. Accordingly, the Court affirmed the trial court's findings that Plaintiff had adversely possessed the platted streets. View "Beach v. Township of Lima" on Justia Law

The Supreme Court consolidated nine separate cases for review. In each, Plaintiffs own property that was subject to state property taxes. Each Plaintiff described the property as âmachinery and equipment.â For the 2008 tax year, the local assessors classified the property for tax-assessment purposes as âindustrial real propertyâ or âcommercial personal property.â Plaintiffs petitioned the relevant boards-of-review to reclassify the property as âindustrial personal property.â That reclassification would permit them to take advantage of recently enacted tax exemptions or credits. In each case, the board denied the request. Plaintiffs then petitioned the State Tax Commission (STC) to reclassify the property. In each case, the STC denied the requests. Plaintiffs then sought and obtained relief in various state circuit courts. The STC appealed to the Court of Appeals, and the court reversed each of the circuit court judgments. The appellate court held that state law barred an appeal of the STC classifications to any state court. Plaintiffs appealed to the Supreme Court, to ask whether the circuit courts have jurisdiction to hear appeals of STC classification decisions. The Supreme Court found the state legislature has not provided for other means for judicial review of STC classification decisions. Accordingly, the Court held that the circuit courts do have jurisdiction over appeals from the STC.

Former Governor Jennifer Granholm appointed Defendant Judge Hugh Clarke to the district court. The Attorney General claimed that Defendant was not entitled to hold office beyond January 1, 2011, and brought a quo warranto action to oust him. The Supreme Court found that Defendant is entitled under state law to hold the office of district judge until January 1, 2013. The Court dismissed the Attorney Generalâs quo warranto action.

This appeal challenged the small employer group health coverage act (Act), which establishes requirements for insurance carriers to offer health insurance benefit plans to small employers in Michigan. Priority Health sought a declaratory judgment from the Office of Financial and Insurance Services (OFIS) so that it could allocate a small portion of insurance premiumsâ costs to employers, lessening the financial burden on employees. Priority Health would not renew contracts with employers who did not agree to pay a portion of the premiums. Both the Court of Appeals and the Commissioner of the Office of Financial and Insurance Services (OFIS) concluded that âminimum employer contribution provisionsâ are inconsistent with the Act. They reasoned that an employerâs failure to pay a minimum percentage of its employeesâ premiums is not among the reasons in the Act that a carrier can use to refuse to renew an insurance plan. The Supreme Court disagreed with the appellate court and OFISâ interpretation of the Act. The Court found that just because the Michigan Legislature did not include an employerâs refusal to pay according to a minimum contribution provision as among the reasons for not renewing a contract for benefits, the [Priority Health] provision was unreasonable or inconsistent with the Act. In general, âunless a provision directly conflicts with the enumerated reasons [of the Act], it may be included in a plan so long as it is reasonable and not inconsistent.â The Court remanded the case to the OFIS for further proceedings.

Plaintiff Great Wolf Lodge of Traverse City, LLC (Lodge) is a water park that sits on former farmland. In 2000, the Lodge annexed a new portion of the former farmland to expand its premises. Defendant Cherryland Electric Cooperative (Cherryland) ran an electric line to the former farm. Cherryland insisted that it had exclusive rights to provide electric service to the Lodge. The Lodge did not protest Cherrylandâs assertion in order to keep its expansion project on track. The new Cherryland contract called for discounted rates. Over the course of the contract, Cherryland unilaterally raised the rates. The Lodge filed suit seeking a refund of excess rates it paid to Cherryland, and to have the ability to choose its own electric service provider. A hearing officer would rule in favor of the Lodge on the rate refund, but would not allow it to choose its own service provider, citing Cherrylandâs âright of first entitlementâ that dated back to when it provided service to the farm. The appellate court reversed the hearing officer. One of the issues on appeal to the Supreme Court was whether Cherrylandâs âright of first entitlementâ stopped when the property ownership changed hands. The Court concluded that the right is not extinguished when ownership changes. The Court reversed the judgment of the appellate court, and reinstated the decision of the hearing officer.

In âPeople v. Helzer,â the Michigan Supreme Court held that when a criminal defendant is charged with being a sexually delinquent person in relation to an underlying sexual offense, separate juries must determine the defendantâs guilt of the sexual delinquency charge and the underlying charge. In this case, Defendant Anthony Breidenbach was convicted by a single jury of "indecent exposure as a sexually delinquent person.â The trial court granted Defendantâs motion for a new trial after the Court of Appeals vacated his conviction on the ground that the first trial violated his rights under the Supreme Courtâs two-jury directive. The prosecutor appealed, arguing that the Helzer case was wrongly decided. The Supreme Court overturned its holding in Helzer. The sexual delinquency statute at issue this case and in the Helzer case, neither explicitly nor implicitly requires separate juries. Because the Helzer rule lacks support in the language of the statute itself, determinations whether separate juries are needed should be made on a case-by-case basis in accordance with state law. The Court granted the prosecutorâs request to for permission to appeal the lower courtâs ruling, and it vacated the trial courtâs granting to Defendant a new trial, reinstating his conviction.