Arbor Crossings Apt LLC v. Township of Muskegon, 334318

Petitioners (Arbor Crossings entities) mailed a Tax Tribunal petition related to the 2016 tax year with an envelope bearing a postage-meter imprint dated May 31, 2016, and a USPS-applied postmark dated June 1, 2016.
MCL 205.735a(6) required petitions to be filed on or before May 31 of the tax year involved to confer Tax Tribunal jurisdiction.
MCL 205.735a(7)(a) treats a petition as filed on time if it is “postmarked by the United States postal service” on or before the deadline. The Tribunal’s administrative rule (TTR 219(5)) treats the USPS postmark as the controlling date.
The Tax Tribunal dismissed the petition as untimely because the USPS postmark was June 1, 2016, after the statutory deadline, despite the meter imprint showing May 31.
Petitioners argued the meter imprint should count as a USPS postmark; they also raised an equal protection challenge claiming disparate treatment of meter-users.
The Court of Appeals reviewed statutory interpretation de novo and the Tribunal’s dismissal for abuse of discretion, and it affirmed the Tribunal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a postage-meter imprint constitutes a postmark "by the United States postal service" under MCL 205.735a(7)(a)	Meter imprint dated May 31 should satisfy the statute and render the filing timely	Statute requires a postmark applied by the USPS itself; meter imprints are applied by the sender under USPS license and are not USPS postmarks	Held: Statute unambiguously requires a postmark by the USPS; meter imprint does not qualify, so filing was untimely
Whether excluding meter postmarks from MCL 205.735a(7)(a) violates equal protection	Treating meter-users differently creates an unjustified classification violating equal protection	Distinction is not a suspect class; requiring an official USPS postmark rationally furthers the statute’s objective of reliable mailing records and preventing stale claims	Held: No equal protection violation; requirement is rationally related to legitimate government interest

Wexford Med Group v. City of Cadillac, 474 Mich 192 (2006) (de novo review of statutory interpretation)
Prof Plaza, LLC v. City of Detroit, 250 Mich App 473 (2002) (review standard for tribunal dismissal for rule noncompliance)
Maldonado v. Ford Motor Co., 476 Mich 372 (2006) (abuse-of-discretion standard explained)
Grimm v. Treasury Dep’t, 291 Mich App 140 (2010) (deference to administrative interpretation unless statutory conflict)
Grass Lake Improvement Bd v. Dep’t of Environmental Quality, 316 Mich App 356 (2016) (statute prevails over conflicting administrative rule)
Lash v. City of Traverse City, 479 Mich 180 (2007) (plain-meaning statutory interpretation)
Elden-Brady v. City of Albion, 294 Mich App 251 (2011) (use of dictionary for statutory terms)
Snead v. John Carlo, Inc., 294 Mich App 343 (2011) (avoid reading beyond clear statutory language)
Walen v. Dep’t of Corr., 443 Mich 240 (1993) (presumption Legislature aware of existing law when enacting statutes)
Carson City Hosp. v. Dep’t of Community Health, 253 Mich App 444 (2002) (legislative intent inferred from use/omission of language)
Jesperson v. Auto Club Ins. Ass’n, 499 Mich 29 (2016) (avoidance of surplusage in statutory interpretation)
Electronic Data Sys. Corp. v. Twp. of Flint, 253 Mich App 538 (2002) (rational-basis review for non-suspect classifications under equal protection)
Crego v. Coleman, 463 Mich 248 (2000) (identifying protected classes for heightened scrutiny)