G. Mennen Williams

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

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

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

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

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

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

This case concerned a challenge by two limited partnerships to special assessments imposed by the City of Novi for road improvements, water mains, and storm sewers, which allocated costs of $13,236.81 per acre to one parcel and $38,769.11 per acre to the other. The Tax Tribunal upheld the assessments after finding that the improvements would confer special benefits, with any increase in property value limited to $5,000 per acre or $15,000 per acre assuming a zoning change to allow development. The court upheld the tribunal's factual findings on value increases as supported by competent evidence but held that the substantial disproportionality between those benefits and the assessment costs rendered the assessments invalid as a matter of law. The decision emphasized that special assessments require a corresponding increase in market value tied to the property's highest and best use.

taxesproperty

The case involved an employee injured while working inside an employer-owned trailer that was registered out-of-state and operated in Michigan for fewer than thirty days. The Michigan Supreme Court held that the employee's personal no-fault insurer, rather than the self-insured employer or the Assigned Claims Facility, was responsible for providing personal protection insurance benefits. The court's reasoning centered on the no-fault act's provisions, determining that vehicles not required to be registered in Michigan and operated for thirty days or fewer are exempt from the mandatory security requirements, so the priority rules directing benefits from the employer's insurer under section 3114(3) did not apply, leaving the employee's personal policy to cover the benefits under section 3101(1).

torts & liabilitybusiness & regulatory

This case involved a dispute between an excess insurer (Commercial Union) and a primary insurer (Medical Protective) over whether the excess carrier could recover from the primary carrier for allegedly failing to defend or settle a medical malpractice claim against their shared insured in good faith. The primary insurer had controlled the defense, which resulted in a default judgment due to the insured's non-cooperation, and it had declined to offer its policy limits or attempt to set aside the default. The Michigan Supreme Court held that an excess insurer may bring such a claim against the primary insurer under the theory of equitable subrogation, stepping into the shoes of the insured who has a recognized right to good-faith defense and settlement. The court declined to recognize a direct tort duty of good faith and due care running from the primary insurer to the excess insurer.

torts & liabilitybusiness & regulatory

This case arose from a 1976 motorcycle accident in which plaintiff Stephen Klanseck was injured after his new Honda GL 1000 fishtailed and fell, allegedly due to a defective front tire; he sued the seller and manufacturer for negligence and breach of warranty. The Michigan Supreme Court addressed whether the trial court properly instructed the jury that it could infer negligence from the plaintiff's failure to obtain a required motorcycle endorsement and that it should consider the plaintiff's duty to mitigate damages by following medical advice. The Court held both instructions were appropriate because evidence raised questions about the plaintiff's experience and skill as a possible cause of the accident and because he had not followed his physician's recommendations. It therefore affirmed the Court of Appeals decision upholding the jury's finding of sixty percent comparative negligence and the resulting damage award. The ruling clarified that a statutory licensing violation may support an inference of negligence when linked to causation, and that mitigation instructions are warranted by even limited evidence of non-compliance with treatment.

torts & liabilityprocedure

The consolidated cases involved two plaintiffs seeking personal injury protection (PIP) benefits under Michigan's no-fault auto insurance statute after being injured in separate accidents; in each instance the insurer delayed or disputed coverage while requesting additional information, and the one-year-back limitation period in MCL 500.3145(1) had expired before suit was filed. The Michigan Supreme Court held that the limitation period is tolled from the date a claimant submits a specific claim for benefits until the insurer formally denies liability, provided the claimant pursues the claim with reasonable diligence. The Court reasoned that this tolling rule aligns with the purposes of the no-fault act and is consistent with its prior decisions applying tolling to contractual and statutory insurance limitation provisions. The Court therefore affirmed the judgment for the plaintiff in Lewis and reversed the accelerated judgment for the defendant in Dionne.

business & regulatoryproceduretorts & liability

This case concerned the applicability of the no-fault insurance act's offset provision, MCL 500.3109(1), to a workers' compensation redemption agreement arising from a work-related auto accident. The Michigan Supreme Court held that the no-fault insurer must subtract the full amount of workers' compensation benefits that would have been payable but for the redemption, rather than only the smaller redemption amount, and reversed the Court of Appeals. The court reasoned that the statute requires subtraction of benefits provided or required to be provided by law, establishing workers' compensation as the primary source of coverage and no-fault insurance as secondary. The decision precludes the plaintiff from recovering from the no-fault insurer amounts for which the workers' compensation carrier was primarily liable.

labor & employmentbusiness & regulatorytorts & liability

The case concerned William Walker's appeal from the Michigan Civil Rights Commission's dismissal of his age discrimination charge against Wolverine Fabricating, raising the question of what 'appeals ... tried de novo' means under Const 1963, art 5, § 29. The Supreme Court held that circuit courts must review CRC decisions by examining the existing record anew to determine whether the factual findings and legal conclusions are supported by competent, material, and substantial evidence, rather than holding a full new evidentiary hearing. It further ruled that the proper defendant in such an appeal is the original respondent (Wolverine), not the CRC itself. The decision rested on analysis of the constitutional text, the history and purpose of the provision as modeled on the prior Fair Employment Practices Act, Constitutional Convention debates, and subsequent legislative interpretations in the Civil Rights Act.

civil rightslabor & employmentprocedure

The case involved the validity of a spendthrift provision in a trust established by Clinton Goodloe Edgar's will, which restricted beneficiaries from transferring their interests in both income and principal. Grandson William Edgar's bankruptcy led to a challenge on whether his interest in the trust could be claimed by the bankruptcy trustee under Michigan law. The Michigan Supreme Court held that spendthrift trusts granting beneficiaries interests in both income and principal are valid, reversing the Court of Appeals. The court reasoned that prior Michigan precedents requiring the gift to be only of income were not controlling, and instead adopted the broader rule from the Restatement of Trusts allowing restraints on both income and principal interests.

property

This case involved a prison inmate challenging the Michigan Department of Corrections' disciplinary directives as invalid for not being properly promulgated as rules under the Administrative Procedures Act (APA). The Department defended the directives under an APA exception for intra-agency communications that do not affect the rights of the 'public,' arguing that inmates are not members of the public. The Michigan Supreme Court affirmed the Court of Appeals, holding that inmates qualify as members of the public for APA purposes and that the exception therefore does not apply. The core reasoning was that legislative intent, shown by several statutes expressly requiring the Department to promulgate APA rules on inmate-related matters, confirms that the APA's rulemaking procedures govern these directives.

criminal lawprocedure

The case consolidated two workers' compensation claims, Peters v. Michigan Bell Telephone Co. and Morrish v. General Motors Corp., in which employees sought benefits for psychiatric disabilities allegedly caused by their jobs. The Michigan Supreme Court addressed whether to revisit its prior three-part test from Deziel v. Difco Laboratories for determining compensability of mental disorders under the pre-1982 version of the Workers' Disability Compensation Act, which required a subjective causal nexus between employment and disability. The Court declined to reexamine or alter that standard, noting that the Legislature had amended the relevant statute effective January 1, 1982, to apply to later injuries, and therefore remanded both cases to the Court of Appeals for further proceedings consistent with the existing Deziel framework.

labor & employment

This case involved a female histotechnologist at Sparrow Hospital who was barred from returning to work after refusing to comply with a dress code that required women to wear full uniforms implying lower status while allowing men to wear lab coats over street clothes. The Civil Rights Commission found the policy discriminatory under the Fair Employment Practices Act and awarded back pay, but the circuit court and Court of Appeals denied back pay. The Michigan Supreme Court held that back pay should generally be awarded upon a finding of unlawful discrimination unless denial would advance the statute's goals of eliminating discrimination and making victims whole; it reversed the denial of back pay on that basis. The Court affirmed the denial of attorney fees because the claimant had not properly preserved the issue before the Commission or on appeal.

civil rightslabor & employment

The consolidated cases involved defendants convicted of two-year misdemeanors under the Penal Code, such as joyriding and resisting an officer, who faced enhanced sentencing as habitual offenders or consecutive sentences under the Code of Criminal Procedure. The Michigan Supreme Court held that these offenses qualify as felonies for purposes of the habitual-offender, probation, and consecutive sentencing provisions because they meet the Code of Criminal Procedure's definition of an offense punishable by more than one year in prison. The court reasoned that the plain language and legislative purposes of the two codes require treating the offenses as misdemeanors within the Penal Code but as felonies within the Code of Criminal Procedure. Additional holdings addressed consecutive sentencing requirements, the meaning of a pending charge, and violations of the right to counsel from ex parte communications about presentence reports. The defendants' convictions and sentences were upheld.

criminal lawprocedure

This case involved the conviction of defendant Jerome Kelly for first-degree felony murder arising from a 1980 robbery in which victim Willie Espy was killed during a home invasion. The Michigan Supreme Court addressed challenges to jury instructions on malice and intent in the context of felony murder and aiding and abetting, as well as the admission of rebuttal testimony and evidence of the defendant's prior convictions. The court held that the instructions, when read as a whole, accurately stated the law regarding the inference of intent from participation in the underlying robbery, and it applied a manifest injustice standard to the unpreserved aiding and abetting claim, finding none occurred. It further concluded that the trial court did not err in allowing the rebuttal witness or the impeachment evidence. The court therefore affirmed the conviction.

criminal lawprocedure

The case concerned whether Michigan's 1935 Prison Reimbursement Act applied only to inmates of the three penal institutions named in one section of the statute or to all inmates in the state prison system, and whether a narrower reading violated equal protection. The Michigan Supreme Court held that the act applied to all state prison inmates and reversed the Court of Appeals decision that had upheld the trial court's finding of unconstitutionality. The court reasoned that the act's title, other sections including section 4a, and the fact that all existing institutions were named in the single procedural provision demonstrated legislative intent to cover the entire prison system rather than create an arbitrary classification. The court remanded the separate vagueness issue to the Court of Appeals without addressing it. The decision turned on statutory interpretation of legislative purpose in a reimbursement action against a prisoner's workers' compensation award.

criminal lawcivil rights