Ronald W Lech II v. Huntmore Estates Condominium Association
315 Mich. App. 288
| Mich. Ct. App. | 2016Background
- Plaintiff Ronald Lech II sued Huntmore Estates Condominium Association; developers Jacobson Ore Creek Land Development, LLC and Scott R. Jacobson defended and moved for summary disposition.
- The trial court awarded the developers sanctions under MCR 2.405 (offer of judgment sanctions) and also awarded prejudgment (judgment) interest under MCL 600.6013 on those sanctions.
- The developers appealed; this Court previously reversed the trial court’s award of judgment interest, but the Michigan Supreme Court vacated that portion and remanded for reconsideration in light of Ayar v Foodland Distributors.
- On remand, the Court of Appeals reconsidered whether MCL 600.6013 allows judgment interest on sanctions awarded under MCR 2.405 to a defendant who never filed a complaint or obtained a money judgment.
- The court focused on the statute’s purpose (compensating a prevailing party for expenses and delay in receiving money damages) and whether the sanctions order is a “money judgment in a civil action.”
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MCL 600.6013 authorizes judgment interest on offer-of-judgment sanctions awarded under MCR 2.405 to a prevailing defendant who never filed a complaint | Lech: Statute doesn’t apply because interest is for money judgments in civil actions tied to plaintiffs’ claims | Developers: Ayar shows interest applies to costs/fees tied to the underlying proceeding; sanctions are part of the judgment so interest should run | Held: Reversed — MCL 600.6013 does not apply; sanctions here are not a money judgment in a civil action and defendants did not incur delay in receiving money damages, so prejudgment interest is inappropriate |
Key Cases Cited
- McCormick v. Carrier, 487 Mich 180 (statutory interpretation standard; plain-meaning rule)
- In re Forfeiture of $176,598, 465 Mich 382 (explaining what constitutes a money judgment and purposes of MCL 600.6013)
- Ayar v. Foodland Distributors, 472 Mich 713 (holding MCL 600.6013(8) applies to attorney fees and costs ordered as mediation/case-evaluation sanctions from date of filing)
- Lech v. Huntmore Estates Condo Ass'n, 310 Mich App 258 (prior Court of Appeals disposition in this case)