Frankfurth v. Detroit Medical Center, 297 Mich. App. 654

Defendants appeal after the trial court granted plaintiffs motion for reconsideration of an order changing venue to Oakland County.
Defendants contend that once a venue change is granted, the trial court loses jurisdiction to entertain further proceedings, including reconsideration.
The Court reviews de novo jurisdiction and statutory interpretation and cites Saba v Gray as controlling precedent.
MCL 600.1651 (as amended) provides that the transferee court has full jurisdiction after a venue transfer, with costs handled under MCL 600.1653.
The order changing venue had immediate effect; therefore the trial court was divested of jurisdiction to entertain the motion for reconsideration, and the motion should have been heard by the transferee court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether venue transfer divests trial court of jurisdiction to rehear reconsideration	Saba requires transferee court to hear related motions	Transferor court retains no jurisdiction after transfer	Yes, transferee court has jurisdiction; trial court erred

Saba v Gray, 111 Mich App 304 (1981) (transfer of venue leaves transferee with full jurisdiction; reconsideration must be heard there)
Brooks v Mammo, 254 Mich App 486 (2002) (rulings become those of the new court after transfer)
Moriarity v Shields, 260 Mich App 566 (2004) (orders effective upon signing; not inherently jurisdictional)
Bers v Bers, 161 Mich App 457 (1987) (reconsideration/relief motions admissible within nonjurisdictional timelines)
Gladych v New Family Homes, Inc, 468 Mich 594 (2003) (textual clarity governs legislative interpretation of statutes)