Justia Michigan Supreme Court Opinion Summaries

The case involves a dispute over the issuance of medical marijuana dispensary licenses in the city of Warren. In 2019, the Warren City Council adopted an ordinance to regulate these licenses, which involved a Review Committee scoring and ranking applications. The Review Committee held 16 closed meetings to review 65 applications and made recommendations to the city council, which then approved the top 15 applicants without further discussion. Plaintiffs, who were denied licenses, sued, alleging violations of the Open Meetings Act (OMA) and due process.The Macomb Circuit Court found that the Review Committee violated the OMA and invalidated the licenses issued by the city council. The court held that the Review Committee was a public body subject to the OMA and that the city council's approval process was flawed. Defendants and intervening defendants appealed, and the Michigan Court of Appeals reversed the trial court's decision. The appellate court held that the Review Committee was not a public body under the OMA because it only had an advisory role, and the city council retained final decision-making authority. The appellate court also upheld the trial court's dismissal of the plaintiffs' due process claims.The Michigan Supreme Court reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that the Review Committee was a public body subject to the OMA because it effectively decided which applicants would receive licenses by scoring and ranking them, and the city council merely adopted these recommendations without independent consideration. The court emphasized that the actual operation of the Review Committee, rather than just the language of the ordinance, determined its status as a public body. The case was remanded to the Court of Appeals to consider whether the open meetings held by the Review Committee cured the OMA violations and to address other preserved issues. View "Pinebrook Warren LLC v. City Of Warren" on Justia Law

The case involves the Michigan Farm Bureau and other agricultural entities challenging new conditions imposed by the Department of Environment, Great Lakes, and Energy (EGLE) in a 2020 general permit for Concentrated Animal Feeding Operations (CAFOs). The new conditions included stricter limits on phosphorus application, setback requirements, and a presumptive ban on waste application during certain months. The plaintiffs argued that these conditions exceeded EGLE’s statutory authority, were contrary to state and federal law, lacked factual justification, were arbitrary and capricious, unconstitutional, and invalid due to procedural failures under the Michigan Administrative Procedures Act (APA).Initially, the plaintiffs sought a contested-case hearing to challenge the permit but then filed for declaratory judgment in the Court of Claims. EGLE moved for summary disposition, arguing that the plaintiffs had not exhausted administrative remedies. The Court of Claims agreed, dismissing the case for lack of subject-matter jurisdiction. The Court of Appeals affirmed this decision but held that the plaintiffs could seek a declaratory judgment under MCL 24.264, provided they first requested a declaratory ruling from EGLE, which they had not done.The Michigan Supreme Court reviewed the case and held that the 2020 general permit and its discretionary conditions were not "rules" under the APA because EGLE lacked the statutory authority to issue rules related to NPDES permits for CAFOs. Consequently, the Court of Claims lacked subject-matter jurisdiction under MCL 24.264. The Supreme Court affirmed the judgment of the Court of Appeals but vacated its holding that the discretionary conditions were rules. The Court emphasized that EGLE must genuinely evaluate the necessity of discretionary conditions in individual cases and that these conditions do not have the force and effect of law. View "Michigan Farm Bureau v. Dept. Of Environment Great Lakes And Energy" on Justia Law

The plaintiffs, current or retired public school superintendents and administrators, filed a lawsuit against the Office of Retirement Services (ORS) alleging that ORS violated the Public School Employees Retirement Act by using salary schedules it created to determine their retirement allowances. The plaintiffs, who worked under personal employment contracts rather than collective bargaining agreements (CBAs), argued that the Retirement Act did not authorize ORS to create these normal salary increase (NSI) schedules and apply them to their pension calculations.The Court of Claims granted summary disposition in favor of the defendants on all claims except for a violation of the Administrative Procedures Act (APA). After cross-motions for summary disposition, the Court of Claims also ruled in favor of the defendants on the APA claim. The plaintiffs appealed, and the Court of Appeals reversed, holding that ORS lacked statutory authority to create NSI schedules and that MCL 38.1303a(3)(f) did not apply to employees under personal employment contracts. The Michigan Supreme Court affirmed the lack of authority for ORS to create NSI schedules but reversed the Court of Appeals' interpretation of MCL 38.1303a(3)(f), remanding the case for further proceedings.The Michigan Supreme Court held that the term "normal salary schedule" is a written document established by statute or approved by a reporting unit’s governing body, indicating the time and sequence of compensation, and applying to a generally applicable job classification rather than a specific employee. The Court clarified that this term is not limited to CBAs and applies to public school employees regardless of their employment contract type. The case was remanded to the Court of Claims to determine whether the plaintiffs were subject to a normal salary schedule as defined. View "Batista v. Office Of Retirement Services" on Justia Law

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