e-Journal Summary

e-Journal Number : 84704
Opinion Date : 11/20/2025
e-Journal Date : 12/04/2025
Court : Michigan Court of Appeals
Case Name : Crawford v. Wayne Cnty. Inv. Group, Inc.
Practice Area(s) : Litigation Real Property
Judge(s) : Per Curiam – Garrett, Patel, and Yates
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Issues:

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

Summary

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.”

Full PDF Opinion