Elliott-Larsen Civil Rights Act (ELCRA) limitations; Court of Claims jurisdiction; Subject-matter jurisdiction; MCL 600.6419; Boler v Governor; Exhaustion of administrative remedies; Huggett v Department of Natural Res; Failure to state claim; MCR 2.116(C)(8); El-Khalil v Oakwood Healthcare, Inc; Statutory interpretation; MCL 600.5805(2); Dine Brands Global, Inc v Eubanks; Revised Judicature Act (RJA)

The court held that the Court of Claims had subject-matter jurisdiction over plaintiff-city’s declaratory and injunctive action against the defendant-Department, but that the city failed to state a claim because the three-year limitations period in the RJA does not apply to administrative ELCRA charge proceedings. The dispute arose from multiple discrimination complaints filed with the Department against the city’s police department and the Department’s continuing investigations and charging decisions under ELCRA. The Court of Claims granted the Department summary disposition under MCR 2.116(C)(4) and (C)(8), concluding the circuit court had exclusive jurisdiction over agency “appeals” and that MCL 600.5805(2) did not apply to the Department’s administrative process. On appeal, the court found the case was not an appeal from a final agency decision and therefore fell within the Court of Claims’ exclusive jurisdiction over equitable and declaratory claims against a state department under MCL 600.6419(1)(a). It explained that plaintiff’s claim was “an action for declaratory judgment and injunctive relief from an administrative agency of this State.” It also held exhaustion was excused because the “expense and inconvenience” of ongoing proceedings was the precise harm the city sought to avoid and the issue was a “solely” legal question of statutory interpretation requiring no agency fact-finding or expertise. The court next held that dismissal under MCR 2.116(C)(8) was proper because the phrase “all actions to recover damages” in MCL 600.5805(2) refers to court actions, not nonjudicial administrative proceedings, relying on the RJA’s stated purpose and the ordinary meaning of “action,” and citing authority that “action” typically “refers to a lawsuit commenced in a court.” It further rejected the city’s absurd-results argument, noting the administrative rules require complaints be filed within 180 days, provide notice upon filing, and do not impose a charging deadline, and it declined to “impose a statute of limitations where one is not applicable.” Affirmed in part and reversed in part.