Dispute over the sale of a vacant lot; Scope of remand order; Rodriguez v General Motors Corp; The law-of-the-case doctrine; Grievance Adm'r v Lopatin; Due process; Principle that a person’s property interest includes title to the property; People v McKendrick; Notice & an opportunity to be heard; Michigan Elec Coop Ass’n v Public Serv Comm’n; Bullington v Corbell; Principle that the due process right to an opportunity to be heard does not require the trial court to hold oral argument; York v Civil Serv Comm’n; Notice under MCR 2.602(B)(3); Effect of a court rule violation; Longworth v Michigan Dep’t of Hwys & Transp; Oral argument; MCR 2.119(E)(3)

The court held that the trial court did not exceed the scope of the remand order by entering an order consistent with the prior opinion and denying plaintiff’s motion for a trial and discovery. It also held that her due process rights were not violated. Defendants, who live a couple of lots away from plaintiff, purchased the vacant lot adjacent to her property during a side lot fair. She sued, claiming they were not proper purchasers under the land bank’s amended policy, which restricted its sales of vacant side lots to adjacent property owners only. The trial court granted plaintiff summary disposition, voided the sale to defendants, and entered an order confirming the sale of the lot to plaintiff. In a prior appeal, the court found that the prior policy (allowing property owners on the same block to purchase vacant lots) applied because it was in effect when they purchased the lot. As such, they were eligible purchasers. On remand, the trial court entered an order denying plaintiff’s motion for a trial and discovery, quieted title to the property to defendants, and reinstated the valid quitclaim deed of the property to them. In this appeal, the court rejected plaintiff’s argument that the trial court exceeded the scope of the remand order by denying her motion for a trial and discovery, despite the court’s directive for further proceedings. The “remand order provided clear instructions for the trial court to follow: quiet title the property to [defendants], reinstate [their] quitclaim deed to the property, and enter a recordable order. That is the scope of the remand, and the trial court could not take any actions inconsistent with those directives.” By requiring the trial court to enter such an order, the court “plainly ordered that judgment was to be entered in favor of [defendants]—there were no issues of fact or law to further litigate because” it determined that the purchase agreement between defendants and the land bank was valid. The trial court complied with the court’s directives “by entering an order that is a near verbatim recitation of” its opinion. The court also rejected plaintiff’s claim that the order to close the case was entered without notice, without an opportunity (1) to produce discovery documents, (2) to file a brief, and (3) for oral argument. It was “evident that the trial court did not enter the order” sua sponte, and “the record indicates that plaintiff had notice of the order.” In addition, despite a technical deficiency with the court rule on notice, she “at least was on notice that the order was submitted under the seven-day provision of the court rules.” Further, the trial court’s “decision to suspend oral arguments on the basis of the COVID-19 pandemic was not an abuse of discretion.” Finally, simply because the “case was disposed of without a trial does not mean that summary disposition was the procedural mechanism” used by the trial court. Affirmed.