Justia Michigan Supreme Court Opinion Summaries

Andrew Czarnecki and Montario Taylor were convicted of first-degree premeditated murder in separate cases. Czarnecki was 19 years old at the time of his crime, while Taylor was 20 years old. Both were sentenced to mandatory life in prison without the possibility of parole (LWOP) as required by Michigan law. They argued that their sentences were unconstitutional under Michigan’s prohibition against cruel or unusual punishment.Czarnecki’s conviction and sentence were affirmed by the Michigan Court of Appeals, which reasoned that the precedent set in People v Hall, which upheld mandatory LWOP for felony murder, remained binding. Taylor’s conviction and sentence were similarly affirmed by the Michigan Court of Appeals, which also relied on Hall and other binding decisions. Both defendants sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court extended its decision in People v Parks, which held that mandatory LWOP for 18-year-olds was unconstitutional, to include individuals who were 19 or 20 years old at the time of their crime. The Court held that mandatory LWOP for 19- and 20-year-olds violates the principle of proportionality and constitutes cruel punishment under the Michigan Constitution. The Court ruled that Czarnecki and Taylor are entitled to individualized sentencing procedures before LWOP can be imposed. The Court reversed the Court of Appeals’ decisions, vacated the defendants’ sentences, and remanded the cases for resentencing in accordance with the new ruling. This decision applies retroactively to cases on collateral review. View "People v. Czarnecki" on Justia Law

Darnell Hairston was seriously injured while operating machinery at Zeeland Farm Soya, Inc. He sued Zeeland Farm Services, Inc. (ZFS) and an employee, later adding Specialty Industries, Inc. as a defendant for negligence and products liability. ZFS settled, but the case against Specialty Industries proceeded to trial, resulting in a jury awarding Hairston over $13 million. Specialty Industries had insurance policies with Burlington Insurance Company and Evanston Insurance Company, which paid their policy limits, leaving a significant portion of the judgment unpaid.The Ottawa Circuit Court denied Hairston and Specialty Industries' motion for supplemental proceedings to pursue a bad-faith refusal to settle claim against the insurers, suggesting they file a separate lawsuit. Hairston then served writs of garnishment on the insurers, which the trial court quashed, stating there was no judgment of bad faith. The trial court also imposed sanctions on Hairston for filing the writs.The Michigan Court of Appeals reversed the trial court's decision to quash the writs, relying on the precedent set in Rutter v King, which allowed bad-faith refusal to settle claims to be litigated through garnishment. However, the Court of Appeals affirmed the sanctions against Hairston.The Michigan Supreme Court reviewed the case and held that unresolved claims of bad-faith refusal to settle are not subject to garnishment under MCR 3.101(G)(1) because they are not sufficiently liquidated. The Court found that the Court of Appeals erred in relying on Rutter, which was decided before the current court rules were adopted. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "Hairston v. Lku" on Justia Law

The case involves Jeffery S. Armstrong, who was charged with carrying a concealed weapon, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony after police discovered a handgun under the passenger seat of a vehicle in which he was sitting. Corporal Treva Eaton claimed she approached the vehicle because she smelled marijuana emanating from it. Armstrong moved to suppress the gun as evidence, arguing it was obtained through a search that violated the Fourth Amendment.The Wayne Circuit Court ruled that Armstrong was seized when officers surrounded the vehicle and that probable cause was required before ordering him out. The court concluded that the smell of marijuana alone did not establish probable cause to search or justify removing Armstrong from the vehicle and ruled that the plain-view exception did not apply. Consequently, the trial court granted Armstrong’s motion to suppress and dismissed the case.The prosecution appealed, and the Michigan Court of Appeals affirmed the trial court’s decision. The appellate court held that the rule from People v. Kazmierczak, which allowed the smell of marijuana alone to establish probable cause, was superseded by the Michigan Regulation and Taxation of Marihuana Act (MRTMA). The court concluded that the smell of marijuana is no longer necessarily indicative of unlawful activity and that the trial court did not clearly err in finding that the gun was not discovered in plain view.The Michigan Supreme Court reviewed the case and held that the Kazmierczak rule is no longer valid in light of the MRTMA. The court ruled that the smell of marijuana is one factor in the probable-cause determination but is insufficient on its own to support a search. The court affirmed the lower courts' decisions, upholding the suppression of the evidence and the dismissal of the charges against Armstrong. View "People Of Michigan v. Armstrong" on Justia Law

John A. Poole was convicted in 2002 of first-degree murder, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony. He was 18 years old at the time of the crime and was sentenced to life imprisonment without the possibility of parole. The Michigan Court of Appeals affirmed his convictions, and the Michigan Supreme Court denied his application for leave to appeal. Poole filed multiple motions for relief from judgment, which were denied.Following the U.S. Supreme Court's decisions in Miller v. Alabama and Montgomery v. Louisiana, which addressed mandatory life sentences for juveniles, Poole sought relief again. The Michigan Supreme Court remanded the case to the Court of Appeals to determine if Poole was entitled to relief under the state constitution's prohibition on cruel or unusual punishment, as extended to 18-year-olds in People v. Parks. The Court of Appeals held that Parks applied retroactively and vacated Poole's sentence, remanding for resentencing.The Michigan Supreme Court reviewed whether Parks should apply retroactively to cases where the period for direct review had expired. The court held that Parks, which extended Miller's protections to 18-year-olds under the Michigan Constitution, announced a substantive rule and should be applied retroactively. The court overruled the state retroactivity analysis in People v. Carp to the extent it survived Montgomery. The court affirmed the Court of Appeals' decision to vacate Poole's sentence and remanded the case for resentencing under MCL 769.25a. View "People Of Michigan v. Poole" on Justia Law

Jeremy Woods was injured in a car accident in 2017 and received medical care from Spine Specialists of Michigan PC. Woods assigned his right to payment of personal protection insurance (PIP) benefits to Spine Specialists, but MemberSelect Insurance Company refused to pay. Spine Specialists sued MemberSelect for payment. MemberSelect argued that the claims were barred by the one-year-back rule, which requires claims to be filed within one year of the medical services being rendered. The trial court granted MemberSelect's motion for summary disposition for services rendered before June 11, 2019, but denied it for services rendered between June 11, 2019, and August 12, 2020.The Court of Appeals affirmed the trial court's decision, reasoning that the tolling provision added to the one-year-back rule in 2019 did not apply to claims that accrued before the amendment's effective date. The court held that PIP benefits accrue when the medical services are rendered, not when payment is denied.The Michigan Supreme Court reviewed the case and held that the tolling provision added to MCL 500.3145 in 2019 does not apply retroactively to causes of action that began to accrue before the amendment became effective on June 11, 2019. The court affirmed the judgment of the Court of Appeals, concluding that the claims for services rendered between June 11, 2019, and August 12, 2020, were barred by the one-year-back rule. The court emphasized that the Legislature did not indicate an intent for the tolling provision to apply retroactively and that applying it retroactively would impose new obligations on insurers for past transactions. View "Spine Specialists Of Michigan PC v. Memberselect Insurance Company" on Justia Law

Natalie C. Nelson was convicted of felonious assault, possession of a firearm during the commission of a felony, and domestic violence. The incident involved Nelson and her boyfriend, Aaron Lewis, at Nelson's home. Nelson discovered Lewis was in contact with a cousin she believed had engaged in child sexual abuse. An altercation ensued, with conflicting testimonies about who was the aggressor. Nelson claimed self-defense, stating Lewis threatened to kill her and physically assaulted her, prompting her to retrieve a firearm.The Wayne Circuit Court sustained the prosecution's hearsay objection when Nelson attempted to testify about Lewis's threat during direct examination. However, Nelson mentioned the threat during recross-examination. The jury was instructed to consider all evidence but not to consider stricken testimony. Nelson was convicted and sentenced to probation, imprisonment, and time served for the respective charges. On appeal, the prosecution conceded the hearsay objection was erroneous. The Michigan Court of Appeals affirmed the convictions, holding the error was not outcome-determinative since the threat was eventually introduced, and jurors are presumed to follow instructions.The Michigan Supreme Court reviewed the case, focusing on whether the trial court's error was outcome-determinative under People v. Lukity. The Court held that the error was outcome-determinative, as the threat was central to Nelson's self-defense theory, and the jury likely did not know whether to consider the once-excluded evidence. The Court reversed the Court of Appeals' judgment and remanded the case for a new trial, emphasizing that the trial court's error deprived Nelson of a meaningful opportunity to support her self-defense claim and likely confused the jury. View "People Of Michigan v. Nelson" on Justia Law

Praxis Packaging Solutions, operating a manufacturing facility, applied for a tax exemption for its manufacturing equipment under Michigan law. The Township of Byron's assessor denied the application, stating the equipment did not meet the statutory definition of eligible manufacturing personal property (EMPP). The denial notice informed Praxis of its right to appeal to the March Board of Review but did not provide specific deadlines or meeting dates. Praxis's agents contacted the assessor for appeal details but were not informed of the deadlines. Praxis submitted an appeal letter after the Board had adjourned, and the Board did not consider the appeal.The Michigan Tax Tribunal dismissed Praxis's petition for lack of jurisdiction, as Praxis had not first appealed to the Board. The Court of Appeals reversed, holding that the Township's notice did not meet statutory requirements and deprived Praxis of due process, thus vesting the Tribunal with jurisdiction.The Michigan Supreme Court reviewed the case and held that the Township's notice did not violate due process. The Court found that the notice, combined with the separate notice of assessment, provided sufficient information about the appeal process. The Court emphasized that due process requires notice reasonably calculated to inform the taxpayer and provide an opportunity to be heard. Since Praxis received actual notice of the Board's meeting dates and the appeal process, the Court concluded that there was no due process violation.The Supreme Court reversed the Court of Appeals judgment and reinstated the Tax Tribunal's dismissal of Praxis's petition for lack of jurisdiction, as Praxis failed to timely protest the exemption denial before the Board. View "Sixarp LLC v. Township Of Byron" on Justia Law

Two companies, Dine Brands Global, Inc. and The Walt Disney Company, filed separate lawsuits against the Michigan State Treasurer, Rachael Eubanks, seeking declaratory and injunctive relief under the Uniform Unclaimed Property Act (UUPA). The Treasurer had initiated multistate examinations of the companies' records to check compliance with the UUPA's reporting and remittance requirements. The examinations, conducted by Kelmar Associates, LLC, identified unclaimed property dating back to 2002. The companies disputed the findings and argued that the statute of limitations barred the Treasurer from collecting the identified property.The Oakland Circuit Court granted summary disposition in favor of the companies, ruling that the examinations were not "actions or proceedings" under the UUPA and did not toll the statute of limitations. The court enjoined the Treasurer from enforcing the collection of the disputed property. The Michigan Court of Appeals affirmed the circuit court's judgments, agreeing that the examinations did not toll the statute of limitations.The Michigan Supreme Court reviewed the case and held that the phrase "action or proceeding" in the UUPA includes both formal lawsuits and administrative procedures like examinations. However, the Court also held that the commencement of an examination does not toll the statute of limitations. The Court noted that the statute of limitations continues to run during an examination and that the Treasurer must initiate an examination within the applicable time frame.The Supreme Court reversed the Court of Appeals' decisions that excluded examinations from the definition of "action or proceeding." The Court remanded the cases to the Court of Appeals to determine whether a holder's duty to comply with the results of an examination is distinct from the annual duty to report and remit unclaimed property, which would affect the statute of limitations for post-examination enforcement actions. View "Dine Brands Global Inc v. Eubanks" on Justia Law

The City of East Lansing entered into an agreement with the Lansing Board of Water and Light (LBWL) in 2016, which included a franchise fee to be charged to LBWL consumers residing within the City. The fee was collected by LBWL and remitted to the City. Plaintiff James Heos, representing a class of LBWL consumers, filed a complaint against the City, alleging that the franchise fee was an illegal tax under the Michigan Constitution's Headlee Amendment and other state laws.The trial court granted summary disposition in favor of the plaintiff on most counts, ruling that the franchise fee was an illegal tax. The Michigan Court of Appeals reversed this decision, directing the trial court to grant summary disposition in favor of the City, concluding that the plaintiff was not a taxpayer and thus his claim was time-barred.The Michigan Supreme Court reviewed the case and held that the franchise fee was indeed a tax because it was used for general revenue-raising purposes, was not proportionate to any costs incurred by the City, and was not voluntary. The Court further held that the plaintiff was a taxpayer because the legal incidence of the fee fell on the LBWL consumers, not LBWL itself. The Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings, allowing the plaintiff to pursue his Headlee Amendment claim. View "Heos v. City Of East Lansing" on Justia Law

Hark Orchids, LP (plaintiff) filed a legal malpractice action against its former attorney and law firm, William Buie and Conklin Benham, PC (defendants). In 2015, defendants represented plaintiff in a workers’ compensation lawsuit brought by a former employee. During the litigation, the former employee informed defendants of additional claims against plaintiff and offered a global settlement for $125,000. Defendants did not inform plaintiff of this offer and settled only the workers’ compensation claim for $35,823.84. Subsequently, the former employee filed another lawsuit against plaintiff, leading to significant additional legal fees for plaintiff. Plaintiff alleged that these fees would have been avoided if defendants had informed them of the global settlement offer.The Kalamazoo Circuit Court granted summary disposition in favor of defendants, reasoning that under the American rule, attorney fees are not recoverable as damages. The Court of Appeals affirmed this decision, agreeing that the American rule barred the recovery of attorney fees as damages in this context. Judge Shapiro concurred, noting that the decision was mandated by precedent but questioned the applicability of the rule given the acceptance of these damages in other states.The Michigan Supreme Court reviewed the case and reversed the lower courts' decisions. The Court held that while the American rule generally prohibits the recovery of attorney fees incurred in litigation, it does not apply to attorney fees that are damages resulting from legal malpractice. The Court clarified that clients can recover reasonable and necessary attorney fees incurred to mitigate the harm caused by legal malpractice. The case was remanded to the trial court for further proceedings to determine if plaintiff could prove the malpractice and the reasonableness of the attorney fees incurred. View "Hark Orchids LP v. Buie" on Justia Law