Calhoun County v. City of Battle Creek
354857
| Mich. Ct. App. | Sep 2, 2021Background:
- Since 1905 the Legislature has required the 37th Circuit Court (Calhoun County) to hold two annual terms in Battle Creek and two in Marshall, and required Battle Creek to provide, free to the county, a courthouse, jail for prisoners during court terms, and a fireproof vault.
- The 1905 statute was reenacted in substantially the same form in the Revised Judicature Act as MCL 600.1513 in 1961.
- In 1992 the county built a new combined courthouse/jail; the county paid construction costs, and the city and county made operational arrangements (including county providing dispatch services in exchange for city access to jail beds).
- After dispatch centralized in 2010, the city began paying the county per diem for 30 jail beds; in 2018 the city stopped paying, and the county sued seeking declaratory relief and restitution theories (unjust enrichment, quantum meruit, conversion).
- The city moved for summary disposition arguing MCL 600.1513 is an unconstitutional local/special act (Const 1963, art 4, § 29) because it singles out Battle Creek and required local voter approval; the trial court agreed and dismissed. The county appealed.
Issues:
| Issue | Plaintiff's Argument (Calhoun County) | Defendant's Argument (City of Battle Creek) | Held |
|---|---|---|---|
| Whether MCL 600.1513 is a local or special act requiring voter approval | Statute governs the state judicial system; funding/locations of circuit court are statewide concerns, so the statute is a general act and valid | The statute names only Calhoun County/Battle Creek and therefore is a local/special act that never received the required voter approval and is void | The statute is a general act; not a local/special act. Trial court erred to dismiss on that ground; appellate court vacated and remanded |
| Whether the statute is effectively repealed, conflicted with other statutes, or relieves the city of payment obligations | MCL 600.1513 remains in force; AG opinion supports the statute’s narrow requirement to furnish jail/courthouse for court terms | City contends later statutory changes and changed circumstances negate or render the statute defunct | Appellate court did not decide those statutory-conflict or restitution claims and remanded for the trial court to address them in the first instance |
Key Cases Cited
- Whallon v. Ingham Circuit Judge, 51 Mich. 503 (1883) (circuit courts are State courts; Legislature may direct places for holding court)
- Hart v. Wayne County, 396 Mich. 259 (1976) (funding and administration of courts is a state concern; statutes affecting funding are general acts)
- People ex rel. Schmittdiel v. Bd. of Auditors of Wayne County, 13 Mich. 233 (1865) (administration of justice is a state concern benefiting the public generally)
- Civil Service Comm. of City of Detroit v. Engel, 187 Mich. 83 (1915) (execution of criminal laws and courts’ criminal jurisdiction are matters of state concern)