Mootness; Final judgment; Jury verdict; MCR 2.515(B); MCL 600.309a; Limited remand; Amended judgment; Offset; Practical legal effect
The court held that plaintiff’s appeal was moot because the trial court entered an amended judgment on remand giving plaintiff the relief it sought. Plaintiff argued the trial court erred by failing to incorporate the jury’s $22,575.09 damages award into the final judgment. The court recognized that under MCR 2.515(B), “a trial court is required to enter judgment in accordance with the jury’s findings,” and that a judgment must “reflect and give effect” to the jury’s factual determinations. But after plaintiff appealed, the court entered a limited remand directing the trial court to reconsider plaintiff’s motion to correct the judgment. On remand, the trial court entered an amended judgment offsetting plaintiff’s $22,575.09 award against defendant’s $36,000 award, thereby “complying with the applicable law and court rules.” Because plaintiff had already received the relief sought on appeal, “there is no longer an existing controversy,” and no appellate decision could have a practical legal effect. Dismissed.
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