Quiet title; Trespass; Judicial disqualification; MCR 2.003(C)(1); Security for costs; MCR 2.109; Summary disposition; MCR 2.116(C)(8); Motion to amend; MCR 2.118(A)(4); Default judgment; Attorney fees; Frivolous filings; MCL 600.2591; MCR 1.109(E)(7)

The court held that defendants-appellants were not entitled to relief from the trial court’s rulings in this neighbor-property dispute over raised garden boxes. Plaintiffs sued for quiet title and trespass after appellants allegedly maintained garden boxes on plaintiffs’ property, and the litigation generated voluminous filings and sanctions. The court first rejected appellants’ judicial-disqualification arguments because the record showed any representation of the judge by cross-defendant-Drain Commissioner’s law firm had ceased, and defendants offered “no evidence” of an ongoing relationship. The court also held that granting a security bond was not extortion because it was “not a malicious threat to injure another person,” and an erroneous ruling is not grounds for disqualification. The court next upheld denial of defendants’ summary-disposition motion. A (C)(8) motion tests plaintiffs’ complaint, and the complaint was legally sufficient where it alleged defendants maintained planter boxes on plaintiffs’ property, satisfying a claim for trespass (“an unauthorized invasion on the private property of another.”) The court also held the trial court did not abuse its discretion by denying leave to amend because defendants “failed to file a proposed amended complaint.” Finally, the court upheld the $2,800 attorney-fee award because defendants’ lengthy filings showed claims and arguments that were “vexatious, frivolous, and objectively incapable of comprehension in most instances.” Affirmed.