Motion for relief from a final order; MCR 2.612(C); Lack of a trial court explanation for its ruling; Woodington v Shokoohi; Moot issue; Michigan Assigned Claims Plan (MACP)

Because the trial court did not “explain its ruling denying plaintiff’s motion for relief from” a final order under MCR 2.612(C), the court vacated the order denying the motion and remanded. The case involved an auto negligence claim against defendant-Hill and a claim for first-party no-fault benefits against defendant-Allstate, an assigned insurer under the MACP. Defaults were entered against Hill. A stipulated order of dismissal was later entered, signed by plaintiff’s counsel and Allstate’s counsel. In her motion for relief from the final order, plaintiff sought to reinstate the case as to Hill only. A motion hearing was held, at the end of which the trial court stated: “So, how about this? Your motion is denied. Have a good day.” The court noted that no “further explanation or legal analysis appears on the record, leaving the basis for the [trial] court’s denial entirely unclear to the parties and to any reviewing court.” Because the court had no “basis for providing meaningful appellate review[,]” it vacated the trial court’s order and remanded with instructions that the trial court “adequately explain the basis of any order it determines is appropriate so the order may be subject to meaningful appellate review.”