Providing summaries of opinions as they are released from the Michigan Supreme Court, Michigan Court of Appeals (published & unpublished), and selected U.S. Sixth Circuit. Over 60,000 cases summarized to date.
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Retaliation claim under the Americans with Disabilities Act (ADA); Vicarious liability; Prima facie case; Whether defendant-former employer established a legitimate, nondiscriminatory reason for plaintiff’s discharge; Pretext; Whether plaintiff was “singled out for adverse treatment”; Hubbell v FedEx SmartPost, Inc; Whether a biased supervisor’s motives could be imputed to the decisionmakers who fired plaintiff; Staub v Proctor Hosp; “Cat’s paw” liability; Proximate causation; Romans v Michigan Dep’t of Human Servs
In an amended opinion, the court again held that plaintiff-Gray established her prima facie ADA retaliation claim that a supervisor’s (defendant-Kyles) “stated reason for reporting her” for alleged timecard irregularities “was a pretext designed to mask retaliation.” Further, she supported her vicarious liability claim against defendant-former employer (State Farm) with “enough evidence to show that Kyle proximately caused her termination” even though he was not among those who made the decision to discharge her. In the amended opinion the majority further discussed in footnote 2 the dissent’s position that Gray had forfeited her “cat’s paw” claim. It also elaborated on its decision to send the vicarious liability issue to a jury, stating that it was not announcing “a bright-line rule that a supervisor’s true-but-selective report will always be the proximate cause of any subsequent adverse employment action.” Instead, it “simply echo[ed]” the Supreme Court’s holding in Staub that “a subsequent investigation that does nothing more than confirm a supervisor’s true-but-selective report is by itself insufficient to break the chain of proximate causation.” The court concluded that it could not answer, as a matter of law, the question “whether Gray’s termination based on” additional discrepancies cited by State Farm “was so ‘unrelated’ to Kyle’s original report and so ‘not foreseeable’ by him that no reasonable factfinder could find proximate causation.” It explained that given that his “report and Gray’s termination both related to Gray’s timekeeping entries, a reasonable jury could find that the former improperly influenced—and was a proximate cause of—the latter.” The court added that its decision in Romans supported rather than undermined its analysis. It again reversed and remanded.
Motion to suppress evidence; Probable cause; Illinois v Gates; Good-faith exception to the exclusionary rule; People v Goldston
In an order in lieu of granting leave to appeal, the court reversed the Court of Appeals judgment (see eJournal # 83614 in the 5/14/25 edition), holding that the trial court erred in denying defendant’s motion to suppress. The court agreed with the Court of Appeals dissent that the search-warrant affidavit did not “connect the firearms and firearm-related items listed in the search warrant with the suspected criminal activity. Therefore, there was not probable cause to believe ‘that contraband or evidence of a crime will be found in a particular place.’” It also agreed with the Court of Appeals dissent that “the affidavit was so lacking in indicia of probable cause that reliance on it was objectively unreasonable. There were no allegations that the defendant used a firearm to commit a crime. Therefore, the good-faith exception to the exclusionary rule did not apply . . . .” The court remanded the case to the trial court.
Divorce; Property distribution; Sparks v Sparks; Spousal support; Attorney fees; MCR 3.206(D)(2)(a) & (b)
The court rejected plaintiff-ex-husband’s argument that “the trial court’s property division was inequitable.” It vacated the spousal support award for defendant-ex-wife solely as to the amount and “remanded for the trial court to provide proper and sufficient findings of fact to justify the particular amount of spousal support it decides should be awarded.” It also vacated the award of attorney fees to defendant and remanded “for the trial court to address the issue again and make proper findings of fact that will facilitate meaningful appellate review.” As to the property division, the court found that a “review of the record, along with the deference afforded to the trial court’s assessment of witness credibility, does not lead to a definite and firm conviction that the trial court made a mistake in finding plaintiff was primarily at fault for the breakdown of the marriage due to his relationship with [nonparty-K], and plaintiff has failed to establish this finding was clearly erroneous.” He next argued “that the trial court clearly erred by finding him at fault for the breakdown of the marriage based on the financial support he provided to” the parties’ adult daughter (A) “because, according to plaintiff, the parties always supported [A] throughout the marriage and defendant was aware of this financial support.” The court found that while “there was somewhat conflicting evidence on this point, the evidence does not lead to a definite and firm conviction that the trial court made a mistake.” As to whether the property distribution was equitable, the court held that contrary “to plaintiff’s assertions, the trial court considered the relevant factors as applicable to the facts and circumstances of the” case. The trial court “also made specific findings of fact regarding the relevant factors.” And the court noted that “there is no rigid framework or mathematical formula for applying the factors.” The real focus of plaintiff’s appellate argument was his claim “that the trial court placed undue weight on the fault findings to reach an inequitable, rather than an equitable, property distribution.” The court concluded that while “the trial court clearly considered fault as a factor, its decision was not based solely on that factor.” Plaintiff did not show “that the trial court placed excessive weight on the issue of fault or that [it] ordered an inequitable property division.” But as to plaintiff’s challenges to the trial court’s spousal support award, the court found that it was “unclear how the trial court arrived at the amount it awarded, making it appear to be an arbitrarily selected amount.” Affirmed in part, vacated in part, and remanded.
Standing & mootness; Alleged procedural irregularities in the trial court proceedings; Limitations on the number of witnesses at an evidentiary hearing; Sufficiency of the evidence that the terms of a land contract were fulfilled; Default on the issue of liability; Failure to provide a transcript
In this real property ownership dispute, the court declined to dismiss the appeal for mootness or lack of standing. It further concluded that defendant could not seek relief “based on a procedure that she helped develop, understood in advance, and never once challenged in the trial court.” The record also showed that she assented to the trial court’s limitation of witnesses at the evidentiary hearing. And there was sufficient record evidence to support the finding that plaintiff fulfilled her obligations under the land contract. Thus, the court affirmed the trial court’s award of the property at issue to plaintiff. She “entered into a land contract agreement with” an LLC regarding the property. She contended that defendant-Spratt and her ex-husband were members of the LLC. Plaintiff’s complaint included a claim for quiet title. On appeal, defendant first argued that plaintiff lacked standing and her claims were moot, so the court must dismiss the appeal and vacate the trial court’s judgment. The court noted that “dismissal of the appeal in this case at defendant’s behest would prevent us from considering the merits of [her] appeal, so the dismissal she seeks would be self-defeating.” Turning to the issue of purported procedural irregularities, it found that defendant waived her right to contest the procedure used by the trial court by failing to raise any objection in the trial court. And while it did not have to address the merits, the court found that “the evidentiary hearing conducted by the trial court had some hallmarks of a bench trial on the issue of quieting title.” The court noted that defendant “did not object to that procedure. Instead, she invited it, and she argued against presenting the claim to a jury.” The court also rejected her sufficiency of the evidence challenge to the trial court’s factual finding “that plaintiff fulfilled all of her obligations under the land contract, so she was entitled to the contested property.” It determined that “the trial court’s finding was supported by plaintiff’s testimony and documents reflecting the series of events that plaintiff described in her testimony.”