Omian v. Chrysler Group LLC
309 Mich. App. 297
| Mich. Ct. App. | 2015Background
- Plaintiff Omian injured back while employed by Chrysler Group, LLC in 2000 and began receiving WDCA benefits.
- Chrysler sought to stop benefits after alleging Omian engaged in criminal activity showing capability to work.
- Medical and vocational evidence conflicted on whether Omian remained disabled.
- Magistrate admitted Exhibit C (guilty plea transcript) and excluded Exhibits B, D and related underlying indictment facts.
- MCAC affirmed the magistrate’s denial to stop benefits and relied on treated physician testimony; remanded by Michigan Supreme Court.
- On appeal, Chrysler challenges the exclusion of indictment-related evidence and argues wrongful-conduct issues were not preserved; court remands for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the MCAC erred in affirming exclusion of Exhibit D and indictment-related evidence | Omian argues indictment facts could be probative of credibility and work capability | Chrysler contends Exhibit D and underlying facts are inadmissible hearsay or irrelevant | Remanded for proper consideration of evidence under correct framework |
| Whether the magistrate erred by excluding relevant indictment facts affecting credibility and work ability | Evidence of bank records and co-conspirator testimony could support credibility | Indictment facts are prejudicial and not properly admitted under MRE rules | Partial reversal/remand to assess relevance of underlying facts |
| Whether the wrongful-conduct rule was preserved and applicable | (Not stated in brief; issue raised) | (Not stated in brief; issue raised) | Not preserved; court would lack authority to review; alternatively merit lacking |
Key Cases Cited
- Moore v Prestige Painting, 277 Mich App 437 (2007) (discusses scope of appellate review of MCAC under substantial evidence standard)
- Mike’s Train House, Inc. v Lionel, LLC, 472 F3d 398 (6th Cir. 2006) (indictments admissible as Rule 803(22) evidence to prove conviction or related facts)
- DiBenedetto v West Shore Hosp, 461 Mich 394 (2000) (standard of review and proper framework for MCAC)
- Manning v Bishop of Marquette, 345 Mich 130 (1956) (wrongful-conduct rule requires injury tied to illegal act)
- Lanigan v Huron Valley Hosp, Inc., 282 Mich App 558 (2009) (evidence relevance and materiality under MRE rules)