Renee Janette Miles v. Secretary of State
329943
| Mich. Ct. App. | Feb 21, 2017Background
- Renee Miles was arrested for operating a vehicle while intoxicated with high BAC and refused a chemical test.
- Secretary of State suspended Miles’s driver’s license for one year beginning May 16, 2015, under statutory implied-consent provisions.
- Miles petitioned the circuit court for a restricted license under MCL 257.323(1); the circuit court denied the petition, finding she had access to alternative transportation.
- Miles appealed the denial to the Michigan Court of Appeals seeking a restricted license.
- By the time of appeal, the one-year statutory suspension had expired (May 15, 2016), and no practical relief could be granted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Appeals should review the denial of a restricted license | Miles argued the denial was erroneous and sought relief | Secretary argued the appeal was moot because the suspension period ended | Appeal dismissed as moot; no relief possible after suspension expired |
| Whether a court should decide moot issues of no practical effect | Miles implicitly sought merits review despite elapsed suspension | Secretary argued courts avoid moot questions unless public significance exists | Court declined to reach merits; no public-significance claim made |
Key Cases Cited
- BP 7 v. Bureau of State Lottery, 231 Mich. App. 356 (Mich. Ct. App. 1998) (appellate courts will not decide moot issues)
- In re Contempt of Dudzinski, 257 Mich. App. 96 (Mich. Ct. App. 2003) (subsequent events that prevent relief render an issue moot)
- Federated Publications, Inc. v. Lansing, 467 Mich. 98 (Mich. 2002) (courts avoid declaring rules with no practical effect unless issue is recurring public significance)
- Herald Co., Inc. v. Eastern Mich. Univ. Bd. of Regents, 475 Mich. 463 (Mich. 2006) (overruling in part on other grounds; cited for limits on review of moot issues)
- Tauriainen v. Secretary of State, 69 Mich. App. 318 (Mich. Ct. App. 1976) (appeal moot where license revocation period expired)
- Siegel v. Hare, 30 Mich. App. 189 (Mich. Ct. App. 1971) (issue moot when restricted-license period elapsed and full license restored)