Mootness; Attorney Gen v Michigan Pub Serv Comm’n; Uniform Condemnation Procedures Act (UCPA) jurisdictional prerequisites; MCL 213.55(1); Board of Cnty Rd Comm’rs for Cnty of Washtenaw v Shankle; Necessity review; MCL 213.56; Nelson Drainage Dist v Filippis; Subject-matter jurisdiction; Void orders; Bowie v Arder; Strict construction of UCPA; Indiana MI Power Co v Community Mills, Inc; Vesting of title; MCL 213.57(1); Goodwill Cmty Chapel v General Motors Corp

The court held that completion of the replacement pipeline did not moot defendants’ appeals because the jurisdictional defects and necessity-review claims could still yield effective relief, so it reaffirmed its prior decision requiring dismissal for lack of subject-matter jurisdiction. On remand from the Supreme Court, the court addressed whether the pipeline’s completion before the landowner and lessee sought leave to appeal rendered the case moot. The court reiterated that an issue is moot only when an event makes it “impossible for the reviewing court to grant relief,” and emphasized that the UCPA “‘is to be strictly construed, and its jurisdictional conditions must be established in fact[.]’” It concluded the appeals were not moot because defendant-Double Eagle’s claim—that plaintiff-Michigan Gas failed to make a statutorily compliant “good faith written offer” to an “owner” (Double Eagle) under MCL 213.55(1) before filing—implicated subject-matter jurisdiction. When “‘a court lacks subject matter jurisdiction,’” “‘any action it takes, other than to dismiss the action, is void,’” and the appellate court’s role is limited to reversing and ordering dismissal. The court also explained that reversal and dismissal “would provide defendants practical relief short of unwinding the” completed project by allowing the parties to address abandonment of the original easement and removal of the original pipeline, potentially avoiding “future litigation” over continued presence of the old line, including possible “continuing trespass” concerns. It rejected reliance on Goodwill as not controlling on mootness here, noting that case involved just-compensation issues and did not present the necessity-review and jurisdiction questions at issue in this proceeding. Affirmed.