Mary S. Coleman

The case was a wrongful death action arising from a fatal car accident caused by preferential icing on an Interstate-75 bridge, where the approaches were clear and dry but the bridge deck had become icy. The plaintiff claimed the Department of State Highways breached its duty to maintain the highway in a reasonably safe condition by using inadequate "watch for ICE on bridge" signs that did not sufficiently alert or instruct motorists. The trial court found the signs inadequate and awarded damages to the plaintiff; the Court of Appeals affirmed the negligence finding but remanded on contributory negligence. The court's core reasoning was that erected traffic signs become part of the highway structure and must effectively warn of hazards under MCL 691.1402, and these signs failed to prompt the necessary driver response of reducing speed.

torts & liability

The case involved a defendant convicted of armed robbery and felony firearm possession after an incident at a dry cleaner where a masked man with a silver pistol took money. The defendant challenged the admission of a pistol found during a warrantless search of his unlocked car parked in his driveway, a post-arrest statement of noninvolvement obtained after he had requested counsel, and the effectiveness of his legal representation. The court affirmed the convictions, holding that the car search was valid either due to exigent circumstances from a possible armed accomplice or as a routine inventory prior to impoundment, that the statement was admissible because the defendant knowingly and voluntarily waived his Miranda rights, and that counsel was not ineffective under the circumstances of the case.

criminal lawgunsprocedure

These consolidated cases under Michigan's no-fault motor vehicle insurance act concerned claims for noneconomic damages arising from automobile accidents, which require plaintiffs to show a 'serious impairment of body function' under MCL 500.3135. The Supreme Court held that whether an injury meets this threshold is a question of law for the court to decide when the facts regarding the extent of the injuries are undisputed or do not straddle the line of seriousness. In Cassidy v. McGovern, the Court reversed the trial court's denial of a directed verdict, ruling that complete fractures of both bones in the lower leg constituted a serious impairment as a matter of law because they significantly interfered with the plaintiff's ability to walk for an extended period. In Hermann v. Haney, the Court reversed summary judgment for the defendants, finding that reasonable minds could differ on whether the plaintiff's temporary neck and back pain from bruises and a bump on the head met the threshold, so the issue should go to a jury.

torts & liabilityprocedure

In People v. Arenda, the defendant was convicted by a jury of three counts of first-degree criminal sexual conduct involving an eight-year-old boy. The trial court granted the prosecutor's motion in limine under Michigan's rape-shield statute, MCL 750.520j, to exclude evidence of the victim's prior sexual conduct with persons other than the defendant, which the defense sought to introduce to explain the child's detailed descriptions of the alleged acts. The Michigan Supreme Court held that the rape-shield law is constitutional and does not violate the Sixth Amendment right to confrontation, reasoning that the right to cross-examine on irrelevant matters is not absolute and may accommodate other legitimate interests, and that reversal was not required on the facts of this case where the proposed evidence was not shown to meet the statutory exceptions for materiality and probative value.

criminal lawprocedure

The case involved defendant Holloway challenging his convictions for possession of heroin and cocaine, claiming that tinfoil packets of drugs retrieved from his mouth should have been suppressed because the arrest on a traffic warrant was a pretext and the mouth search violated the Fourth Amendment. The court affirmed the convictions, ruling that the arrest pursuant to a valid warrant was lawful irrespective of the officers' possible additional motives and that the search was reasonable. The core reasoning centered on the officers' observations of film canisters with drug residue, the defendant's unusual silence and chewing motions, their prior knowledge of the defendant, and exigent circumstances including the risk of evidence destruction and potential harm to the defendant, which justified the brief forcible extraction of the packets. The opinion also addressed application of the plain-view doctrine in the context of the arrest and search.

criminal lawprocedure

The case concerned whether a patient who signed arbitration agreements with two hospitals upon admission was required to arbitrate a medical malpractice claim against an independent consulting physician who had separately agreed to arbitrate with the hospitals. The patient alleged negligence in failing to monitor for side effects of a tuberculosis drug that allegedly caused vision loss, and the trial court denied the physician's motion to compel arbitration while the Court of Appeals reversed. The Supreme Court affirmed, holding that the patient was bound by the agreements. The forms, approved by the state insurance commissioner under the medical malpractice arbitration act, expressly covered disputes with independent staff doctors and consultants who had agreed to arbitrate, and the statute's definitions and provisions extended arbitration to such providers rendering care in the hospital setting.

healthcareproceduretorts & liability

The case involved the Michigan Attorney General suing Diamond Mortgage Company and its officers under the quo warranto statute and the Michigan Consumer Protection Act, alleging usurious lending practices and misleading loan documents in mortgage transactions. The trial court dismissed the case, and the Court of Appeals affirmed, but the Michigan Supreme Court reversed, holding that the action could proceed in court without first exhausting administrative remedies before the Department of Licensing and Regulation, that the company was not exempt from the Consumer Protection Act, that the relevant provision was one of venue rather than jurisdiction, and that quo warranto was appropriate for alleged pervasive corporate illegality. The court reasoned that the administrative scheme did not bar the Attorney General's claims for injunctive relief, penalties, and corporate dissolution, and that the exemptions and procedural bars asserted by defendants did not apply.

business & regulatoryprocedure

This products liability case arose after a forklift operator was killed when his vehicle veered off the road, struck a post, and rolled over, pinning him beneath its overhead guard; his widow sued the manufacturer, Allis-Chalmers, alleging that the forklift was defectively designed because it lacked a factory-installed driver restraint such as a seat belt or cage enclosure. The trial court granted a directed verdict for the defendant, which the Court of Appeals affirmed. The Michigan Supreme Court affirmed the directed verdict, holding that the plaintiff's single expert witness provided no factual data on the magnitude of risks, the utility or relative safety of proposed alternative designs, or the reasonableness of installing restraints as standard equipment. The Court noted that the manufacturer had offered a cage option and that the expert had not shown why the employer, rather than the manufacturer, was not better positioned to decide on such equipment. It concluded that the evidence failed to create a jury question on whether the design posed an unreasonable risk of foreseeable injury.

torts & liability

This case concerned whether the state could be held liable under the highway defect statute and wrongful death act for damages including loss of companionship and society after a fatal collision allegedly caused by an improperly maintained guardrail on a state expressway. The plaintiff, as personal representative of the decedent survived by a spouse and minor children, sought such damages from the State Highway Commission after the trial court granted summary judgment limiting recovery to bodily injury and property damage. The Michigan Supreme Court reversed, holding that the state is liable for proven loss-of-companionship damages. The court reasoned that the highway liability statute places governmental entities on equal footing with private tortfeasors, the wrongful death act expressly authorizes these damages, and neither statutory text nor governmental-immunity policy bars their recovery against the state.

torts & liability

The case involved two defendants charged with first-degree criminal sexual conduct who sought to enter guilty but mentally ill pleas despite lacking memory of the offenses due to factors like intoxication. The Michigan Supreme Court held that a defendant with amnesia is not barred from such a plea under the relevant statute, and a trial court may accept it if a factual basis is established through the preliminary examination transcript, witness testimony, or other evidence, while also complying with plea-taking rules and statutory safeguards for mental illness determinations. The court reversed the Court of Appeals rulings that had found the factual bases insufficient and reinstated the defendants' plea-based convictions and sentences. The decision emphasized adherence to existing court rules like GCR 1963, 785.7 and statutory requirements for guilty but mentally ill pleas.

criminal lawprocedure

The case involved a Detroit police officer who retired in 1962, accepted a civilian city position, and signed a waiver of his pension benefits during that employment based on city policy. After a 1973 Court of Appeals decision invalidated similar waivers, the plaintiff demanded his withheld benefits in late 1973 and filed suit for mandamus in 1974 seeking over $21,000 in accrued payments. The Michigan Supreme Court held that the claim was barred by the six-year statute of limitations applicable to contract actions. The core reasoning was that statutory limitation periods are treated as conclusive rules of repose that run without interruption absent specific tolling exceptions such as fraudulent concealment, none of which applied here despite equitable arguments regarding laches or estoppel.

labor & employmentprocedure

The case concerned whether the Michigan Tax Tribunal had exclusive jurisdiction over a property owner's challenge to a special assessment levied by the City of Novi for a public improvement, or whether the claim could instead be brought in circuit court seeking injunctive relief. The court held that the Tax Tribunal Act grants the tribunal exclusive jurisdiction over direct review of such governmental decisions regarding special assessments. The reasoning centered on the Act's language and legislative history, which aimed to consolidate tax and assessment disputes in a specialized quasi-judicial forum to ensure prompt, consistent, and expert resolution, replacing prior fragmented remedies like protests in circuit court or injunction actions. The opinion addressed both the parties' arguments and an alternative view that the tribunal's authority was limited to ad valorem taxes, ultimately rejecting the narrower interpretation.

taxespropertyprocedure

This case concerned township and city treasurers and landowners challenging 1975 drain taxes collected by the Wayne County Drain Commissioner, alleging that the use of special assessments to fund administrative expenses constituted constructive fraud and should instead come from general taxation funds, with the collected monies held in escrow. The Michigan Supreme Court addressed whether the circuit court had jurisdiction, whether the treasurer plaintiffs had standing, and whether a 30-day statute of limitations applied. The Court held that the action was at least partly equitable and thus properly in circuit court rather than exclusively before the Tax Tribunal, that the treasurers' standing could not be dismissed without further evidentiary review given their potential public duties, and that the asserted limitations period did not bar the claims due to the fraud allegations. The core reasoning focused on the scope of equitable jurisdiction over special assessments involving fraud claims, the circumstances under which public officials may challenge assessments commensurate with their duties, and the inapplicability of short limitations periods to such equitable claims.

taxesprocedure

The case People v. Fields was a criminal prosecution appealed to the Michigan Supreme Court. The court reviewed the Court of Appeals decision in People v Fields, 101 Mich App 287; 300 NW2d 548 (1980) and concluded that it was correct. The Supreme Court therefore remanded the matter to the trial court for entry of an order dismissing the case and discharging the defendant. All seven justices concurred in the memorandum opinion affirming the lower appellate ruling.

criminal law

The case concerned whether Michigan's School Code of 1955 required a vote of school tax electors in the transferor district before detaching property to another district, when prior transfers combined with the current one exceeded 10% of the district's taxable valuation. The Supreme Court of Michigan affirmed the Court of Appeals, holding that the statute mandates an elector vote only if the specific area in a single transfer exceeds 10% of the latest taxable valuation of the entire district. The core reasoning rested on the plain statutory language referring to "the area to be detached" in the context of one proposed action, which did not support a cumulative reading of multiple transfers, and the absence of clear legislative intent to depart from that literal interpretation.

propertyelections

The case concerned whether the Chamblis rule, which bars jury instructions on lesser included misdemeanors when the charged felony carries more than two years' imprisonment, applies to bench trials. After a bench trial, the judge acquitted the defendant of four felonious assault counts but convicted him of the misdemeanor of intentionally discharging a firearm without malice; the Court of Appeals vacated the conviction under Chamblis. The Michigan Supreme Court reversed, holding that the Chamblis rule applies only to jury trials. The court reasoned that the rule was adopted under the court's supervisory power as a prophylactic measure to prevent jury confusion and compromise verdicts, policies that do not apply when a judge serves as factfinder because judges are presumed to know the law and are less susceptible to confusion. The court also rejected an equal-protection challenge, finding a rational basis for distinguishing bench from jury trials.

criminal lawprocedure

This case involved a Florida resident who was injured in Florida while working on a dredge and who sued the defendant company in Michigan state court under the federal Jones Act and general maritime law for negligence and unseaworthiness. The defendant, a New Jersey corporation doing business in multiple states, moved to dismiss on grounds of forum non conveniens, arguing that Florida was the appropriate forum because the plaintiff resided there, the incident occurred there, most witnesses and medical treatment were in Florida, and the defendant was amenable to suit in Florida. The Michigan Supreme Court reversed the lower courts' decisions denying the motion, holding that it was an abuse of discretion to retain the case in Michigan. The court reasoned that the doctrine of forum non conveniens applies to Jones Act cases in state court, that the plaintiff's choice of forum is entitled to less weight when there is no significant connection to Michigan, and that the burden on Michigan courts and the parties outweighed any interest in litigating there.

procedurefederal power

In LeBlanc v. State Farm Mutual Automobile Insurance Company, the Michigan Supreme Court considered a dispute over no-fault auto insurance benefits after a pedestrian accident where the plaintiff, who was over 65, incurred medical expenses covered by both Medicare and a no-fault policy from the defendant insurer. The insurer refused to pay for expenses reimbursed by Medicare, arguing for a mandatory set-off under section 3109(1) of the no-fault act as federal governmental benefits. The Court of Appeals had upheld the set-off, but the Supreme Court reversed, holding that Medicare payments qualify as "other health and accident coverage" under section 3109a, permitting optional coordination with no-fault benefits at the insured's election rather than automatic subtraction. The core reasoning centered on statutory interpretation of the two provisions and legislative intent to treat Medicare like private health coverage eligible for coordination at reduced premiums.

healthcarebusiness & regulatorytorts & liability

The case concerned the constitutionality of Michigan's dormant mineral act, which provides that severed oil and gas interests created before 1963 are deemed abandoned and vest in the surface owner if the mineral owner fails to record a claim or take other specified actions for 20 years. The Michigan Supreme Court held that the act does not unconstitutionally impair the obligation of contracts under the state and federal constitutions. The court reasoned that the obligation to record is minimal and does not substantially impair existing contractual relationships, drawing on precedents upholding similar recording requirements and statutes of limitations as rationally related to addressing problems with dormant mineral interests.

property

The case involved a police officer convicted of conspiracy to obstruct justice after agreeing not to arrest a person in exchange for money. The Court of Appeals reversed the conviction, holding that Wharton's Rule barred the conspiracy prosecution. The Michigan Supreme Court affirmed that decision, reasoning that a specific statute (MCL 750.123) expressly covers an officer receiving a reward or promise for omitting an arrest, so the conduct could not be charged as conspiracy to obstruct justice under the general statute and Wharton's Rule principles prevented evading the legislative punishment scheme through a conspiracy charge.

criminal law