e-Journal Summary

e-Journal Number : 84141
Opinion Date : 08/07/2025
e-Journal Date : 08/19/2025
Court : Michigan Court of Appeals
Case Name : Heart of the Lakes Cmty., Inc. v. West Bloomfield Sch. Dist.
Practice Area(s) : Litigation Open Meetings Act
Judge(s) : Per Curiam - Young, Garrett, and Wallace
Full PDF Opinion
Issues:

Preliminary injunction; Hammel v Speaker of the House of Reps; Jurisdiction; Relief under the Open Meetings Act (OMA); MCL 15.263; MCL 15.270(1) & (2); MCL 15.271(1) MCL 15.273(1) & (2); Madugula v Taub; The 60-day limitations period; MCL 15.270(3)(a); Likelihood of success on the merits; MCL 15.263(1)-(3); “Public body”; MCL 15.262(a); “Decision”; MCL 15.262(d); Distinguishing Booth Newspapers, Inc v University of MI Bd of Regents, Pinebrook Warren, LLC v City of Warren, & Exclusive Capital Partners, LLC v Royal Oak; Public announcement of bids; MCL 380.1267(6); Balance of harms between parties; Harm to the public interest; Other adequate legal remedy; Temporary restraining order (TRO)

Summary

The court held that the trial court lacked jurisdiction to invalidate defendant’s (school district and board members) decision to demolish an old school and did not otherwise abuse its discretion by denying plaintiffs’ motion for a preliminary injunction and dissolving the TRO it had previously entered. Thus, it affirmed. Plaintiffs sought the preliminary injunction to prevent the demolition of the old school building. On appeal, as a preliminary matter, the court found that the trial court correctly determined it lacked jurisdiction to invalidate the decision to demolish the school “because plaintiffs failed to file their lawsuit within the 60-day limitations period.” Next, the court found that the trial court properly concluded that plaintiffs were unlikely to prevail on the merits with respect to Count I. It noted that the evidence did “not show that defendants violated the OMA with respect to the demolition and asbestos-abatement bids. The Board did not delegate its functions . . . , it held a study session and a board meeting at which it heard comments from the public, and no evidence indicate[d] that any deliberations or decisions were made behind closed doors.” In addition, the trial court did not clearly err by determining that “the balance of the harms weighed against a preliminary injunction” or that “the public interest would be harmed if a preliminary injunction was issued.” Finally, the court found that “a preliminary injunction was inappropriate regarding Counts II through VII regardless of the likelihood of the claims’ success on the merits.”

Full PDF Opinion