Principal residence exemption (PRE); Tax Tribunal (TT) jurisdiction; MCR 2.116(C)(4); MCL 205.731; MCL 211.7cc; Governmental immunity; Governmental Tort Liability Act (GTLA); MCL 691.1407(2); Gross negligence; Intentional infliction of emotional distress (IIED); Equitable estoppel; Injunctive & declaratory relief; Motion for leave to amend; Motion for relief from judgment; MCR 2.612(C)(1)(a); Unpreserved due-process claim

The court held that plaintiff’s claims arising from the denial of her PRE were properly dismissed because the circuit court lacked jurisdiction over her request to establish entitlement to the exemption, defendant-township assessor was entitled to governmental immunity, and her remaining tort and equitable theories failed as a matter of law. Plaintiff alleged that defendants-Brooks and Tucker questioned whether she resided in West Bloomfield Township and that the assessor (Scripture) reported her alleged nonresidency to the Department of Treasury, resulting in loss of her PRE. As to her request for a declaration establishing her residency and PRE entitlement, the court concluded that the TT possessed exclusive and original jurisdiction. Subject-matter jurisdiction “‘cannot be conferred by consent, by conduct or by waiver’” or be acquired by estoppel. Scripture was also entitled to governmental immunity. Reviewing PRE eligibility and recommending denial fell within his statutory authority, and plaintiff alleged at most that he was negligent or mistaken. “Mere negligence is not enough to overcome governmental immunity.” The court further upheld dismissal of plaintiff’s IIED claim because discussions concerning her residency and Scripture’s report to Treasury were not sufficiently extreme or outrageous. It deemed her limitations argument abandoned and, as to the invasion-of-privacy claim, moot. Her equitable-estoppel theory also failed because “equitable estoppel is not an independent cause of action,” and she could not reasonably rely on an earlier residency determination as permanently establishing PRE eligibility when the exemption could be reviewed annually. Likewise, injunctive and declaratory relief were remedies rather than independent causes of action and could not survive after dismissal of the substantive claims. Finally, the trial court did not abuse its discretion by refusing further amendment after plaintiff missed the deadline it had provided. Counsel’s workload and the circumstances surrounding his medical treatment did not establish excusable neglect on this record. Affirmed.