City of Ann Arbor v. St James Church of God in Christ Ypsilanti, 330336

City sued St. James Church (a nonprofit corporation) and Pastor Melvin Lewis seeking nuisance abatement and permission to demolish a dangerous building on the Church’s property.
Lewis, a nonlawyer and the Church’s resident agent, filed an answer pro se purporting to represent the Church.
Because a corporation cannot be represented by a nonattorney, the Church failed to properly defend and a default was entered against the Church; the trial court then entered default judgment permitting demolition.
The Church later retained counsel and moved to set aside the default judgment, arguing good cause (Lewis’s confusion/ignorance) and a meritorious defense (corrected plans).
The trial court denied the motion to set aside, concluding Lewis’s unilateral lack of legal knowledge did not constitute good cause; motion for reconsideration denied.
The building was demolished; the Church appealed the denial of relief from the default judgment and collateral consequences (liens, costs) remain at issue.

Issue	Plaintiff's Argument (City)	Defendant's Argument (Church/Lewis)	Held
Whether trial court abused discretion by denying motion to set aside default judgment	Default properly entered because Church (a corporation) did not timely defend; no good cause shown	Good cause: Lewis was reasonably "confused"/unaware that a nonlawyer cannot represent a corporation; deserves relief	No abuse of discretion; ignorance of law by nonlawyer agent is not good cause to set aside default
Whether the Church showed a meritorious defense sufficient to set aside default	Not reached by trial court; City contends none	Church asserted City failed to explain site-plan rejections and Church corrected defects once informed	Court did not decide meritorious-defense issue because good-cause failure was dispositive
Whether prior cases recognizing "confusion" as good cause apply here	Those cases involved unusual procedural circumstances, not a unilateral misunderstanding	Lewis’s confusion is analogous and should be excused	Distinguishable; prior cases involved non‑unilateral, unusual circumstances; not applicable here
Whether procedural due‑process error from not ruling on stay warrants reversal	City: moot because Church cannot obtain relief; no prejudice	Church: trial court errored by not ruling on stay; due process violated	Moot/unpreserved; no relief available so appellate court declines to decide

Detroit Bar Ass'n v. Union Guardian Trust Co., 282 Mich. 707 (1938) (nonlawyer may not represent a corporation; unauthorized practice of law)
Fraser Trebilcock Davis & Dunlap PC v. Boyce Trust 2350, 497 Mich. 265 (2015) (corporation has separate legal existence and must be represented by counsel)
Saffian v. Simmons, 477 Mich. 8 (2007) (abuse-of-discretion standard for postjudgment relief; trial court discretion to evaluate reasonableness of excuses)
Barclay v. Crown Bldg. & Dev., Inc., 241 Mich. App. 639 (2000) (Michigan disfavors setting aside properly entered defaults; good cause standard explained)
Reed v. Walsh, 170 Mich. App. 61 (1988) (a lay party’s lack of legal knowledge will not necessarily be a reasonable excuse to set aside default)
Alken‑Ziegler, Inc. v. [Defendant], 461 Mich. (2000) (party is responsible for actions/inactions of its agents)