The case concerns a challenge by the American Beverage Association to a Michigan statute requiring certain beverage containers sold in the state to carry a unique mark allowing reverse vending machines to identify them as Michigan containers, aimed at preventing fraudulent redemption of out-of-state bottles under the state's Bottle Bill. The court held that the provision, M.C.L. § 445.572a(10), is not facially discriminatory against interstate commerce or extraterritorial in its reach. It rejected arguments that the law violates the dormant Commerce Clause on those grounds but found a genuine issue of material fact remains as to whether any burden on interstate commerce is clearly excessive relative to the local benefits of reducing fraud and protecting state revenues, precluding summary judgment under the Pike balancing test.
The case involved Evanston Insurance Company filing suit to vacate an appraisal award of actual cash value for fire damage to property owned by Cogswell Properties, LLC, and seeking a declaratory judgment that its liability under the policy was limited to Cogswell's purchase price for the property. The parties filed cross-motions for summary judgment, and the court granted each in part and denied each in part, while dismissing as premature Cogswell's request for penalty interest. The court vacated the appraisal award and remanded the matter to the panel for a new determination. The core reasoning was that the panel had committed a manifest mistake by failing to apply the broad evidence rule to consider all relevant evidence of value, including the property's low purchase price, as previously directed by the court.
This case concerns a bankruptcy trustee's attempt to avoid a transfer of the debtor's marital residence to his ex-wife's family trust, which occurred as part of a divorce settlement in exchange for cancellation of a $123,000 loan. The bankruptcy court dismissed the preference claim under 11 U.S.C. § 547(b), finding no diminution of the estate due to the property's tenancy-by-the-entireties status and rejecting the debtor's schedules as unreliable evidence. On appeal, the district court vacated that ruling and remanded, holding that the bankruptcy court clearly erred by wholly disregarding the schedules without specific proof of inaccuracies and that further analysis was needed on elements like insolvency and whether the creditor received more than in a hypothetical Chapter 7 liquidation. The court noted that transfers of entireties property can potentially be avoided as preferences and emphasized that the divorce context did not automatically preclude such analysis.
This case concerns Claude Zain McCollum's civil lawsuit against Detective Sergeant Rodney Bahl following McCollum's conviction for the 2005 sexual assault and murder of professor Carolyn Kronenberg at Lansing Community College. McCollum alleged that Bahl suppressed exculpatory video surveillance analysis showing McCollum was in another building at the time of the crime, fabricated aspects of his confession and other evidence, and caused his nearly two-year incarceration before exoneration based on the same video evidence. On Bahl's motion for summary judgment, the court granted dismissal of claims related to purple fiber evidence and state-law abuse of process but denied dismissal of § 1983 claims for fabricating the confession and improper detention as well as state-law claims for false arrest, malicious prosecution, intentional infliction of emotional distress, and gross negligence, finding genuine issues of material fact when viewing the record in McCollum's favor.
This case concerns an insurance coverage dispute in federal court between Lansing Community College (LCC) and National Union Fire Insurance, where the court first had to determine whether it had diversity jurisdiction. The key issue was whether LCC qualifies as an arm of the State of Michigan, which would prevent it from being treated as a citizen of the state for diversity purposes. Applying the four factors from Ernst v. Rising, the court concluded that LCC is not an arm of the state. The most important factor—the state's potential legal liability for a judgment against LCC—did not support arm-of-the-state status, as Michigan has no legal obligation to pay such judgments. The other factors, including how state law describes community colleges, the local election of their boards, and their primarily local function in providing post-secondary education, further confirmed that LCC is a citizen subject to diversity jurisdiction.
The case involves Ken Moore suing his former employer Hexacomb Corporation for allegedly violating the Americans with Disabilities Act and Michigan's Persons With Disabilities Civil Rights Act by failing to accommodate his osteoarthritis and terminating his employment. Moore and Hexacomb filed cross-motions for summary judgment. The court denied both motions, finding that Moore had exhausted his administrative remedies for the termination claim and that there were genuine issues of material fact regarding whether Moore was a qualified individual with a disability who could perform the essential functions of his job with accommodation.