Clohset v. No Name Corp.
302 Mich. App. 550
Mich. Ct. App.2013Background
- District court entered a stipulated consent judgment on Oct 1, 1999 in favor of Clohsets; district court later renewed the judgment in 2009.
- Clohsets sought enforcement in district court after defendants defaulted on settlement, with monetary amount exceeding district court’s general limit.
- District court transferred the case to circuit court under MCR 2.227(A)(1) arguing lack of subject-matter jurisdiction, which circuit court then addressed on the merits.
- Court on remand considered whether district court’s specific jurisdiction under Chapter 57 of the RJA permits a consent judgment with a monetary amount above the general limit.
- Supreme Court vacated and remanded; court ultimately held district court had subject-matter jurisdiction and consent judgment could be enforced despite general limits.
- Court remanded to district court for reinstatement and enforcement of the consent judgment
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court had subject-matter jurisdiction to enter the consent judgment | Clohset argues district court’s specific RJA role supported jurisdiction | No Name/Goodmans contend lack of general jurisdiction barred the judgment | District court had jurisdiction under Chapter 57; transfer to circuit was error |
| Whether defendants may collaterally attack the consent judgment | Clohset enforcement of the judgment should stand given proper consent | Defendants may challenge only on direct appeal or proper motion | Defendants cannot collaterally attack the consent judgment; error challenge must be direct or timely, not collateral |
| Whether circuit court erred by addressing merits after transfer | Remand should have reimposed district court's jurisdiction | Circuit court was proper forum after transfer | Circuit court erred by ruling on merits; case should have been returned to district court |
| Whether statute/court rule changes alter outcome on remand | Remand provisions do not change district court’s jurisdictional authority | Remand could alter jurisdictional analysis | Neither MCL 600.5739(1) nor MCR 4.201(G)(2)(b) required different outcome; district court authority remains |
Key Cases Cited
- Bruwer v Oaks (On Remand), 218 Mich App 392 (1996) (district court had specific jurisdiction over Chapter 57 matters; jurisdictional priority over general limits)
- Dresselhouse v Chrysler Corp, 177 Mich App 470 (1989) (abuse of discretion standard for trial court judgments; error in trial court cannot be parachuted on appeal)
- Bowie v Arder, 441 Mich 23 (1992) (though lack of jurisdiction cannot be raised collaterally; errors in exercise of jurisdiction may be challenged on direct appeal)
- Jackson City Bank & Trust Co v Fredrick, 271 Mich 538 (1935) (lack of jurisdiction cannot be collaterally attacked when jurisdiction attached; challenge on direct appeal required for errors in exercise of jurisdiction)
- In re Hatcher, 443 Mich 426 (1993) (subject-matter jurisdiction is determined by pleadings; authority continues once possessed)
- Altman v Nelson, 197 Mich App 467 (1992) (subject-matter jurisdiction exists when court may adjudicate the class of claims; voidness requires lack of jurisdiction)