957 N.W.2d 341
Mich. Ct. App.2020Background
- Plaintiffs (two long‑term MDOC corrections officers at Macomb Correctional Facility) alleged dog allergies from an inmate‑run leader‑dog training program in their housing unit and requested reassignment as a disability accommodation.
- MDOC temporarily moved them but returned them to dog units; MDOC denied further accommodation and plaintiffs filed EEOC charges (probable cause found); DOJ declined to pursue the matters. Plaintiffs sued the Facility warden (official capacity), MDOC, and the State alleging violations of Michigan disability law, Title I of the ADA, and §504 of the Rehabilitation Act, seeking declaratory and injunctive relief (and other relief).
- Defendants moved for summary disposition under MCR 2.116(C)(4), arguing Michigan courts lack subject‑matter jurisdiction over ADA and Rehabilitation Act claims against the State or its officers because of sovereign immunity and the Court of Claims Act’s exclusive jurisdiction.
- Trial courts denied the motions; defendants appealed (consolidated), raising only lack of subject‑matter jurisdiction.
- The Court of Appeals addressed whether Michigan circuit courts have concurrent jurisdiction with federal courts to hear (a) Title I ADA injunctive/declaratory claims against a state official in his official capacity and (b) §504 Rehabilitation Act claims against the State or its actors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether circuit courts have subject‑matter jurisdiction over Title I ADA claims seeking injunctive/declaratory relief against a state official in official capacity | Circuit courts have concurrent jurisdiction; ADA authorizes suits in state courts and Ex parte Young allows official‑capacity injunctive relief | Sovereign immunity and the Court of Claims Act deprive circuit courts of jurisdiction over federal ADA claims against the State or its officers | Held: Circuit courts may hear Title I ADA injunctive/declaratory claims against state officials; Congress did not intend to limit jurisdiction to federal courts and Court of Claims statutes do not strip circuit court concurrent jurisdiction |
| Whether §504 Rehabilitation Act claims must be brought exclusively in federal court | State courts are presumptively competent to hear federal claims; §2000d‑7’s reference to federal court does not oust state courts | §2000d‑7 shows Congress intended federal forum; sovereign immunity limits state court actions | Held: Circuit courts retain concurrent jurisdiction over §504 claims; §2000d‑7 does not expressly or implicitly make federal jurisdiction exclusive |
| Whether MCL 600.6440 (Court of Claims Act) requires plaintiffs to file federally cognizable federal claims in federal court rather than in circuit court | MCL 600.6440 only bars filing such claims in the Court of Claims when a federal remedy is available; it does not bar circuit court jurisdiction | MCL 600.6440 (and Court of Claims exclusivity) requires federal filing and divests circuit courts | Held: MCL 600.6440 prohibits filing in Court of Claims when a federal remedy exists but does not divest circuit courts of their presumptive concurrent jurisdiction |
Key Cases Cited
- Office Planning Group, Inc. v. Baraga‑Houghton‑Keweenaw Child Dev. Bd., 472 Mich. 479 (2005) (framework for determining whether Congress intended to confine federal‑law claims to federal courts)
- Peden v. City of Detroit, 470 Mich. 195 (2004) (state courts may entertain ADA claims; federal and state jurisdictional considerations)
- Bd. of Trs. of Univ. of Ala. v. Garrett, 531 U.S. 356 (2001) (Title I monetary damages claim against states not validly abrogated by Congress; injunctive relief against state officials remains available)
- Ex parte Young, 209 U.S. 123 (1908) (official‑capacity injunctive relief doctrine permitting suits against state officers to enjoin ongoing violations of federal law)
- Mims v. Arrow Fin. Servs., LLC, 565 U.S. 368 (2012) (statutory grant of a state‑court forum does not imply exclusivity absent clear congressional intent)
- Burt v. Titlow, 571 U.S. 12 (2013) (state courts presumptively competent to adjudicate federal claims)
- Florida Prepaid Postsecondary Educ. Expense Bd. v. Coll. Sav. Bank, 527 U.S. 666 (1999) (Congress may condition federal funds on waiver of sovereign immunity under the Spending Clause)