Justia Michigan Supreme Court Opinion Summaries

The defendant was convicted by a jury in the Wayne Circuit Court of three counts of torture, three counts of unlawful imprisonment, one count of felonious assault, and one count of possession of a firearm during the commission of a felony. The defendant held his wife and their two children at gunpoint in their home, threatening to kill them and burn down the house. The court sentenced the defendant to various prison terms for these convictions and placed him on the sex-offender registry as a Tier I offender under the Sex Offenders Registration Act (SORA) because two of the unlawful imprisonment convictions involved minors.The defendant appealed his convictions, arguing insufficient evidence for the torture convictions and that his placement on the sex-offender registry violated constitutional protections against cruel or unusual punishment. The Michigan Court of Appeals affirmed the convictions but remanded the case to remove the defendant from the sex-offender registry, concluding that imposing SORA for a crime lacking a sexual component constituted cruel or unusual punishment under the Michigan Constitution. The defendant sought further appeal, and the prosecution cross-appealed regarding the removal from SORA.The Michigan Supreme Court reviewed the case and held that the application of SORA to non-sexual offenders like the defendant constitutes cruel or unusual punishment under the Michigan Constitution. The Court found that the 2021 SORA, despite legislative intent as a civil regulation, imposed punitive effects that outweighed this intent when applied to non-sexual offenders. The Court emphasized that the registry's requirements and the social stigma attached to being labeled a sex offender were excessive and not rationally related to the nonpunitive purpose of public safety. Consequently, the Court vacated the part of the Court of Appeals opinion that extended beyond non-sexual offenders and affirmed the judgment that the defendant and similar offenders should be removed from the sex-offender registry. View "People Of Michigan v. Lymon" on Justia Law

Karen Carter filed a lawsuit against DTN Management Company after she slipped and fell on an icy sidewalk at her apartment complex on January 10, 2018. She alleged negligence and breach of statutory duties. Carter filed her complaint on April 13, 2021. DTN Management moved for summary disposition, arguing that the claim was time-barred by the three-year statute of limitations. The trial court agreed and granted the motion.The Court of Appeals reversed the trial court's decision, holding that Administrative Order No. 2020-3, which extended certain filing deadlines during the COVID-19 state of emergency, was within the Michigan Supreme Court's authority. The appellate court found that the order excluded days from the computation of time under MCR 1.108, making Carter's filing timely. DTN Management appealed to the Michigan Supreme Court.The Michigan Supreme Court held that Administrative Orders 2020-3 and 2020-18 were constitutional exercises of the Court's authority under Const 1963, art 6, §§ 4 and 5. The Court determined that these orders affected the computation of time rather than tolling the statute of limitations, which is within the Court's power to regulate practice and procedure. The Court concluded that Carter's lawsuit was timely filed, as the days during the state of emergency were not counted in the limitations period. Consequently, the trial court's grant of summary disposition was improper. The Court of Appeals judgment was affirmed, and the case was remanded to the Ingham Circuit Court for further proceedings. View "Carter V DTN Management Company" on Justia Law

Jane Doe, a minor, alleged that the Alpena Public School District and the Alpena Board of Education created a sexually hostile educational environment by failing to adequately respond to repeated unwanted sexual contact by another student, John Roe. Doe claimed this violated the Elliott-Larsen Civil Rights Act (ELCRA). The defendants sought summary disposition, arguing that student-on-student harassment is not actionable under the ELCRA and that Doe failed to meet the elements of a hostile-environment claim.The Alpena Circuit Court granted the defendants' motion for summary disposition, agreeing that the ELCRA does not cover student-on-student harassment and that Doe did not establish a genuine issue of material fact. The Michigan Court of Appeals partially reversed, holding that the ELCRA could apply under the in loco parentis doctrine, but affirmed the summary disposition on the grounds that the defendants took appropriate remedial action.The Michigan Supreme Court reviewed the case and held that the ELCRA does not provide a vicarious-liability cause of action against educational institutions for student-on-student sexual harassment. The Court found no statutory basis for applying the in loco parentis doctrine to impose vicarious liability on schools under the ELCRA. The Court reversed the part of the Court of Appeals' judgment that relied on vicarious liability and vacated the part affirming summary disposition. The case was remanded to the Court of Appeals to determine if the trial court correctly granted summary disposition under a direct liability theory and whether such a claim exists under the ELCRA. View "Doe V Alpena Public School District" on Justia Law

In the first case, Kent County foreclosed on the homes of Matthew Schafer and Harry and Lilly Hucklebury for unpaid taxes. The properties were sold at auction in 2017, and the county retained the surplus proceeds beyond the owed taxes. Following the Michigan Supreme Court's 2020 decision in Rafaeli, LLC v Oakland Co, which held that retaining surplus proceeds from tax-foreclosure sales is an unconstitutional taking, the Schafer plaintiffs filed a lawsuit seeking those proceeds. The Kent Circuit Court denied the county's motion to dismiss, ruling that Rafaeli applied retroactively. The Court of Appeals affirmed this decision.In the second case, the state of Michigan, acting as the foreclosing governmental unit (FGU) for Shiawassee County, foreclosed on property owned by Lynette Hathon and Amy Jo Denkins in 2018. The state retained the surplus proceeds from the sale. The Hathon plaintiffs filed a class action lawsuit in the Court of Claims, which certified the class and denied the state's motion for summary disposition. After Rafaeli, the plaintiffs moved for summary disposition, and the state moved to revoke class certification. The Court of Claims granted the state's motion to revoke class certification but later recertified an amended class. The Court of Appeals affirmed the Court of Claims' decisions.The Michigan Supreme Court held that Rafaeli applies retroactively to claims not yet final as of July 17, 2020. The court also ruled that MCL 211.78t, which provides a procedure for processing claims under Rafaeli, applies retroactively, while the new two-year limitations period in MCL 211.78l applies prospectively. Claims that arose before December 22, 2020, but expired between that date and the court's decision must be allowed to proceed if filed within a reasonable time. The court affirmed the Court of Appeals' decision in Schafer and remanded the case for further proceedings. In Hathon, the court vacated the Court of Appeals' judgment affirming class recertification and remanded the case to the Court of Claims for reconsideration. View "Schafer v. Kent County" on Justia Law

The defendant was convicted by a jury of being a violent felon in possession of body armor after driving from Michigan into Canada without paying a toll. He was arrested by a Canadian customs agent, Officer Lavers, and returned to the U.S., where American customs agent Officer Stockwell took custody of him and a bulletproof vest. The Canadian government did not allow Lavers to testify at trial. The defendant moved to exclude evidence of the vest, arguing it violated the Confrontation Clause since Lavers could not testify. The trial court denied the motion but barred testimony about statements made by Lavers. At trial, Stockwell testified about taking custody of the defendant and the vest based on communications with Lavers. Other evidence included the defendant’s statements about wearing the vest due to threats.The trial court denied the defendant’s motion to vacate the conviction, but the Michigan Court of Appeals reversed, finding that Lavers’s out-of-court statement was testimonial and admitted in violation of the Confrontation Clause. The court also found the error was not harmless beyond a reasonable doubt because the only other evidence supporting the vest’s admission violated the corpus delicti rule. The case was remanded for a new trial. The prosecution appealed to the Michigan Supreme Court.The Michigan Supreme Court held that a defendant’s right to confrontation is violated when a trial witness’s testimony introduces the substance of an unavailable witness’s out-of-court statement if it leads to a clear and logical inference that the statement was testimonial. The court affirmed that the Confrontation Clause was violated but found the Court of Appeals erred in applying the corpus delicti rule to the defendant’s statements. The case was remanded to the Court of Appeals to determine if the Confrontation Clause violation was harmless beyond a reasonable doubt. View "People of Michigan v. Washington" on Justia Law

Eric Bradley and Jacqueline Chuang filed a lawsuit in the Washtenaw Circuit Court against Linda Frye-Chaiken for breach of contract, specific performance, and promissory estoppel. The dispute arose from an agreement to sell a condominium in the Cayman Islands, which Frye-Chaiken later hesitated to complete following her mother's death. Frye-Chaiken claimed the contract was obtained through coercion or fraud and counterclaimed that her diminished capacity due to her mother's illness invalidated the agreement. The trial court granted summary disposition in favor of Bradley and Chuang, ordering specific performance of the contract and dismissing Frye-Chaiken's counterclaims.The Court of Appeals affirmed the trial court's decision, supporting the summary disposition and the order for specific performance. Bradley and Chuang then sought sanctions, arguing that Frye-Chaiken's defenses and counterclaims were frivolous. Frye-Chaiken hired Barry Powers to represent her in the sanctions proceedings. The trial court awarded $16,714.27 in attorney fees to Bradley and Chuang, holding Frye-Chaiken, Powers, and her previous attorneys jointly and severally liable for the sanctions.The Michigan Supreme Court reviewed the case and held that under MCR 1.109(E) and MCL 600.2591, sanctions for frivolous filings should only be imposed on the attorney who signed the frivolous documents and the represented party. The court found that Powers did not sign any of the frivolous documents and was only involved in litigating the amount of sanctions. Therefore, the trial court abused its discretion by holding Powers jointly and severally liable for the sanctions. The Michigan Supreme Court reversed the Court of Appeals' decision and remanded the case for further proceedings consistent with its opinion. View "Bradley v. Frye-Chaiken" on Justia Law

Police officers observed a parked car with its engine running in an elementary school parking lot at 10:00 p.m. They parked their patrol car 10 feet behind the parked car at a 45-degree angle, with headlights and a spotlight directed at the car. The officers approached the car, noticed signs of intoxication from the driver, and arrested him after he failed field sobriety tests. The driver later consented to a blood draw and admitted to drinking alcohol.The Oakland Circuit Court denied the defendant's motion to suppress evidence of intoxication, arguing it was the result of an unlawful seizure. The Court of Appeals denied interlocutory leave to appeal. The Michigan Supreme Court remanded the case to the trial court to determine when the defendant was first seized for Fourth Amendment purposes. On remand, the trial court granted the defendant's motion to dismiss, finding that the defendant was seized when the patrol car parked behind him. The Court of Appeals reversed, holding that the defendant was not seized when the patrol car parked 10 feet away at a 45-degree angle.The Michigan Supreme Court held that a seizure may occur when a police vehicle partially blocks a defendant’s egress if the totality of the circumstances indicates that a reasonable person would not have felt free to leave. The Court found that the defendant was seized before the officers observed signs of intoxication, considering the police conduct, the time, and the setting. The judgment of the Court of Appeals was reversed, and the case was remanded to determine whether the officer had reasonable suspicion of criminal conduct when the defendant was initially seized. View "People of Michigan v. Duff" on Justia Law

In the first case, a young woman with severe headaches due to excess brain fluid had a shunt catheter implanted. She later returned to the emergency room with worsening symptoms, and a brain scan was performed. Dr. Swofford, a diagnostic radiologist, verified the scan results, but the emergency procedure to relieve her brain pressure failed, and she died. The plaintiff, representing the decedent's estate, sued Dr. Swofford and his practice for medical malpractice. The trial court ruled that the relevant specialty was diagnostic radiology, not neuroradiology, and thus excluded the plaintiff's neuroradiologist expert. The Court of Appeals reversed, finding neuroradiology to be the relevant specialty, allowing the expert to testify.In the second case, a plaintiff sued Dr. Colton for medical malpractice after multiple rhinoplasties resulted in a nasal deformity. Dr. Colton was certified in otolaryngology and facial plastic and reconstructive surgery. The plaintiff's expert, Dr. Armstrong, had the same certifications but spent most of his time on otolaryngology. The trial court found the expert's qualifications unclear and denied a motion to strike his testimony. The Court of Appeals reversed, ruling that the relevant specialty was facial plastic and reconstructive surgery, and excluded the expert because he did not spend the majority of his time in that specialty.The Michigan Supreme Court reviewed both cases. It held that the Woodard decision, which conflated "specialty" and "subspecialty," was incorrect. The Court clarified that "specialty" refers to general board certifications recognized by major certifying entities and does not require matching subspecialties. In Stokes, the Court affirmed that diagnostic radiology was the relevant specialty, allowing the neuroradiologist to testify. In Selliman, the Court remanded the case to determine whether facial plastic and reconstructive surgery is a subspecialty, requiring further fact-finding by the trial court. View "Estate Of Horn v. Swofford" on Justia Law

In 2005, the defendant's infant daughter, Nakita, died while under the defendant's care. The defendant claimed Nakita was choking, but after an autopsy, the medical examiner concluded that Nakita died from shaken baby syndrome (SBS). The defendant was convicted of first-degree felony murder in 2006 and sentenced to life in prison without parole. In 2017, the defendant filed a motion for relief from judgment, presenting new expert testimony that challenged the SBS diagnosis and suggested alternative causes of death, such as choking.The Wayne Circuit Court held an evidentiary hearing but ultimately denied the defendant's motion, ruling that the new expert testimony was inadmissible under Michigan Rule of Evidence (MRE) 702. The Michigan Court of Appeals affirmed this decision, agreeing that the biomechanical engineering evidence was inadmissible and that the new evidence did not make a different result probable on retrial.The Michigan Supreme Court reviewed the case and found that the trial court abused its discretion by excluding the expert testimony. The Court held that the biomechanical engineering evidence was relevant and reliable under MRE 702, as it was based on sufficient facts and reliable principles. The Court also determined that the new evidence, including the changed opinion of the original medical examiner and other expert testimony, made a different result probable on retrial. The Court concluded that the defendant had demonstrated "good cause" and "actual prejudice" as required by Michigan Court Rule (MCR) 6.508(D)(3) and satisfied all four prongs of the test established in People v. Cress.The Michigan Supreme Court reversed the lower courts' decisions and remanded the case for a new trial, allowing the new expert testimony to be considered. View "People Of Michigan v. Lemons" on Justia Law

Cleveland Stegall was employed at an FCA vehicle assembly plant through a staffing agency, Brightwing. In late 2015, FCA announced plans to eliminate Stegall’s shift by summer 2016. In April 2016, Stegall raised concerns about asbestos in the workplace to his FCA supervisors, who promised air quality tests but did not provide results. Stegall continued to request the results and threatened to file complaints with OSHA and Michigan OSHA. He was terminated on June 17, 2016, and subsequently filed a discrimination complaint with Michigan OSHA, alleging retaliation for his asbestos concerns.The Oakland Circuit Court granted summary disposition for both defendants, ruling that Stegall’s public-policy claim was preempted by the Whistleblowers’ Protection Act (WPA) and that internal complaints could not support a public-policy claim. The Michigan Court of Appeals affirmed, agreeing that the public-policy claim was preempted and could not be based on internal reporting. The Michigan Supreme Court reversed in part, holding that internal reporting could support a public-policy claim and remanded for further consideration of whether the claim was preempted by other laws.On remand, the Court of Appeals concluded that Stegall’s public-policy claim was preempted by OSHA and MiOSHA, as these statutes provided exclusive remedies for retaliation. The Michigan Supreme Court reviewed the case and held that the remedies under OSHA and MiOSHA were inadequate and thus not exclusive. Therefore, Stegall’s public-policy claim was not preempted. The case was remanded to the trial court to determine if there was a genuine issue of material fact regarding Stegall’s claim of wrongful termination in violation of public policy. View "Stegall V Resource Technology Corporation" on Justia Law