Whether plaintiff-former employee’s civil rights violation claims were time-barred by an employment application’s six-months limitations period; Rayford v American House Roseville I, LLC; Waiver; Retroactive applicability of Rayford

On remand from the Supreme Court for reconsideration in light of Rayford, the court held that plaintiff-former employee did not waive any reliance on Rayford and that Rayford applied here. It also denied defendant’s request that it conclude the employment application’s “shortened limitations period here was reasonable.” Thus, it vacated the trial court’s grant of summary disposition for defendant and remanded the case “to the trial court for further proceedings consistent with” Rayford and this opinion. Plaintiff asked the court to apply Rayford “and remand the case back to the trial court for a review of whether plaintiff’s filing was reasonable, as that term was described in Rayford. Defendant” offered multiple reasons why the court should not do so and should instead affirm summary disposition. The court found no merit in its argument that plaintiff waived reliance on Rayford. Plaintiff contended throughout the proceedings “that the shortened limitations period set forth in his employment agreement was against public policy.” Defendant’s argument that “Rayford should be applied only to cases filed after its date of issuance” (7/31/25) also failed. The court found Rayford did apply here. “As a matter of common sense,” the Supreme Court specifically vacated the court’s prior judgment in this case “and remanded for reconsideration in light of its Rayford decision. If the Supreme Court intended for Rayford to apply only to cases initiated after the date of that decision, then there would have been little reason to remand here.” The court added that “it has long been established that ‘the general rule is that judicial decisions are to be given complete retroactive effect.’” Finally, it declined to “short-circuit the regular litigation process by taking up” the question of whether the limitations period here was reasonable “in the first instance on appeal, especially given the possibility that” making this determination “might require further factual development.”