Kefer Brown v. Liberty Mutual Insurance, 328783

Plaintiff sued Liberty Mutual in July 2014 seeking no-fault PIP benefits for a 2012 auto accident; Liberty Mutual never appeared, asserting improper service.
The trial court issued a scheduling order on October 10, 2014 directing plaintiff to serve that order on other parties; plaintiff did not serve it.
Plaintiff moved for default judgment in December 2014; the court issued a notice in March 2015 warning of dismissal for lack of progress; plaintiff did not respond.
The court dismissed the case without prejudice on June 12, 2015 for failure to comply with the scheduling order.
Seventeen days later plaintiff moved to reinstate and again sought default judgment but provided no persuasive explanation for the failure to serve the scheduling order; counsel told the court at hearing he had "no compelling reasons."
The trial court denied reinstatement; the court of appeals affirmed, applying MCR 2.502 and Wickings-factor analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying plaintiff's motion to reinstate after dismissal for lack of progress	Plaintiff argued the failure to serve the scheduling order was an inadvertent procedural error (checkbox hard to see) and thus there was good cause to reinstate	Defendant argued plaintiff failed to show good cause and the issue was unpreserved below	Court held no abuse of discretion: plaintiff failed to show good cause; many Wickings factors weighed against reinstatement

Wickings v. Arctic Enterprises, Inc., 244 Mich. App. 125 (Mich. Ct. App. 2001) (establishing factors for evaluating "good cause" to reinstate an action dismissed for lack of progress)
Maldonado v. Ford Motor Co., 476 Mich. 372 (Mich. 2006) (standard and deference for abuse of discretion review)
Woodard v. Custer, 476 Mich. 545 (Mich. 2006) (explaining when a trial court's decision falls outside range of principled outcomes)