Quiet title & adverse possession action concerning a vacant lot; Withdrawal of counsel; MCR 2.117(C)(2); In re Withdrawal of Attorney; “Good cause”; MRPC 1.16(b)(6); Ambrose v Detroit Edison Co; Setting aside default; MCR 2.603; Good cause or a meritorious defense; Shawl v Spence Bros; Quiet title; Prima facie title; MCL 211.78l(1); Adverse possession; MCL 600.5801(4); Kipka v Fountain; Temporary restraining orders (TROs); MCR 3.310(B)(1); Mootness

Holding that plaintiff failed to establish title to the vacant lot and could not meet the requirements for adverse possession, the court affirmed the trial court’s rulings on withdrawal of counsel, default, summary disposition, and TROs. Plaintiff brought a quiet-title and adverse-possession action concerning a vacant Detroit lot adjacent to her house, claiming that her mother’s quitclaim deed and later use of the property gave her ownership rights. The trial court allowed her attorney to withdraw, set aside defaults against defendants, granted summary disposition to defendant-Brazier (titleholder of the vacant lot) and defendant Hall (titleholder of the house lot), and granted in part and denied in part plaintiff’s requests for TROs. On appeal, the court held the trial court did not abuse its discretion by allowing withdrawal because plaintiff’s own statements showed “there was a breakdown of the attorney-client relationship and that she had rendered counsel’s continued representation unreasonably difficult.” It further upheld the order setting aside Brazier’s default, explaining that while process issues existed she “ultimately filed an answer, and nothing in the record indicates she knowingly or intentionally filed an untimely answer.” As to quiet title, the court held plaintiff failed to make a prima facie showing, emphasizing that under MCL 211.78l(1) “fee simple title to the property vests in the foreclosing governmental unit” once foreclosure is complete, and thus plaintiff’s equitable interest under the land contract was extinguished. Her adverse possession claim also failed because “considering the many years that the governmental entities owned the vacant lot after the 2005 foreclosure, and that Brazier acquired title only in 2021, plaintiff cannot establish the requisite 15-year period.” Finally, the TRO issue was deemed moot, since Brazier prevailed on title.