Management Solutions Holdings, LLC v. City of Southfield
2:24-cv-10279
| E.D. Mich. | Nov 21, 2024Background
- Management Solutions Holdings (MSH), and its members Aaron Morris and Shannon Steel, operated a hotel in Southfield, Michigan, after entering into a franchise agreement with Ramada Wyndham Hotels.
- The City of Southfield initially granted them a temporary certificate of occupancy pending upgrades, which MSH claims to have completed by March 2020.
- Plaintiffs allege that, beginning in spring 2020, City agents harassed them through code enforcement actions, ticketing, police site visits, and eventually closing the hotel and leading to arrests.
- Plaintiffs assert these actions led to a breach of their franchise agreement and were motivated by racial animus, citing a derogatory comment by a City employee.
- Plaintiffs brought claims for constitutional violations under the Fifth and Fourteenth Amendments (via § 1983), as well as state law claims.
- The City moved to dismiss. Plaintiffs did not respond, making the motion unopposed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Individual Standing | Morris/Steel harmed by City's actions | Only LLC suffered direct injury | No standing for individuals |
| § 1983 Claim against Municipality | City's custom/policy caused harm | No policy/custom; no pattern of illegality | Dismissed; no viable claim |
| Equal Protection (Selective Enforcement) | Actions motivated by racial animus | No evidence of disparate treatment | Dismissed; insufficient facts |
| State Law Claims Jurisdiction | (Not specifically briefed) | Decline supplemental jurisdiction if no federal claims | Dismissed without prejudice |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for plausible claims survives a motion to dismiss)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires concrete, particularized injury)
- Warth v. Seldin, 422 U.S. 490 (1975) (plaintiffs must assert their own legal rights/interests)
- Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978) (municipalities liable under § 1983 only for policy/custom, not vicarious liability)
- Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) (injury in fact must be concrete and particularized)