
Powers v. Detroit Automobile Inter-Insurance Exchange
Michigan Supreme Court · 1986-12-30 · cited 118×
This case consolidated multiple disputes in which insured drivers sought no-fault benefits after accidents involving vehicles owned by relatives living in the same household, which were not the specific cars named in their policies. The insurance companies denied coverage, arguing that the policy definitions of "owned automobile" and "nonowned automobile" created an exclusion for such household vehicles. The Michigan Supreme Court analyzed the policies as contracts of adhesion, noting that they were drafted by insurers without negotiation and that ordinary English meanings of the terms created ambiguity when read against the insurers' technical interpretations. The court held that the exclusions were invalid and that coverage applied because the policies did not clearly limit protection in the manner claimed by the insurers.
business & regulatorytorts & liability
Larson v. Johns-Manville Sales Corp.
Michigan Supreme Court · 1986-12-29 · cited 111×
This case involved consolidated wrongful death actions against asbestos manufacturers, in which the estates of insulation workers sought damages after the workers developed asbestosis (and in two cases, related cancers) from occupational exposure but had not filed prior personal injury suits. The trial court granted summary judgment to defendants on statute-of-limitations grounds, finding the actions barred because they accrued at the time of exposure or diagnosable injury rather than discovery, and the Court of Appeals largely affirmed. The Michigan Supreme Court reversed, holding that under the discovery rule a cause of action for asbestosis accrues when the claimant knows or reasonably should know of the disease, and that a separate cause of action for subsequently developing cancer accrues independently upon discovery of the cancer even if no asbestosis suit was timely filed. The court reasoned that the relevant Michigan statutes and precedents require accrual based on discovery in latent-disease cases rather than the date of the underlying wrong, and that asbestosis and asbestos-related cancer are distinct diseases with separate limitation periods.
torts & liabilityprocedure
Eyde Bros. Development Co. v. Eaton County Drain Commissioner
Michigan Supreme Court · 1986-12-29 · cited 25×
This case involved a dispute between Eyde Brothers Development Company and the Eaton County Drain Commissioner over Blue Cross's plan to construct a sewer line under Mt. Hope Highway, which runs through Eyde's property, after negotiations for an alternative connector sewer failed. Eyde argued that the highway easement established by user did not permit sewer construction without its consent, an easement or release under the Drain Code, or condemnation proceedings with compensation, and that its grass-mowing activities limited the easement width. The Michigan Supreme Court reversed the Court of Appeals and ruled in favor of the defendants, holding that a public highway easement by user includes the right to install sewers, that a majority vote resolution from the relevant governing body suffices without the fee owner's consent, that no compensation is required for such use within the public easement, and that periodic mowing does not rebut the statutory presumption of a sixty-six-foot width. The decision rested on interpretations of Michigan highway law, the Drain Code of 1956, and precedents regarding dedications by user.
property
In Re Seitz Estate
Michigan Supreme Court · 1986-12-08 · cited 12×
This case involved a dispute over the remaining proceeds of a life insurance policy after a divorce, between the insured's second wife (as personal representative of the estate) and the contingent beneficiary (son from first marriage). The Michigan Supreme Court held that the contingent beneficiary was not entitled to the proceeds because the beneficiary designation required the primary beneficiary to predecease the insured for the contingent to take, which did not occur, even though the primary beneficiary was disqualified by the divorce judgment. The core reasoning was that the explicit precondition in the designation form must be satisfied, leading the proceeds to pass to the insured's estate instead.
family lawproperty
Automatic Music & Vending Corp. v. Liquor Control Commission
Michigan Supreme Court · 1986-11-24 · cited 16×
This case concerned whether a video draw poker machine at a licensed club was an illegal gaming device under Michigan's gambling statute, MCL 750.303, after Liquor Control Commission officers confiscated it following play that awarded free replays. The Michigan Supreme Court reversed the lower courts and held that the machine violated the statute because it involved consideration (payment to play), chance (random card distribution), and a prize or reward (free replays), meeting the common-law definition of gaming. The court further ruled that the machine did not qualify for the statutory exception in subsection (2), as it could accumulate more than 15 replays, featured a knock-off mechanism to erase replays without play, and recorded unplayed replays, and it upheld the statute against constitutional challenges for vagueness. The decision reversed the Court of Appeals and reinstated the Commission's finding of a violation.
criminal lawbusiness & regulatory
Sheridan Road Baptist Church v. Department of Education
Michigan Supreme Court · 1986-11-24 · cited 33×
This case involved a challenge by two Baptist churches operating nonpublic schools against Michigan's statute requiring state certification of teachers in such schools, on grounds that the requirement violated their rights to free exercise of religion under the First, Ninth, and Fourteenth Amendments to the U.S. Constitution and related provisions of the Michigan Constitution, and also created an establishment clause violation through excessive government entanglement. The Michigan Supreme Court upheld the certification requirement, holding that it did not discriminate against the plaintiffs or compel adherence to any religious viewpoint. Applying the balancing test from Wisconsin v. Yoder and Sherbert v. Verner, the court concluded that the state's interest in ensuring all teachers meet minimum qualifications outweighed any slight burden on the churches' religious exercise, and found no establishment clause violation.
religious libertycivil rights