Younkin v. Zimmer
497 Mich. 7
Mich.2014Background
- Plaintiff Lawrence Younkin injured his back while working in Genesee County and filed a workers’ compensation claim.
- Michigan Administrative Hearing System announced reorganization, closing the Genesee County hearing site and reassigning Genesee cases to the Dimondale hearing office (~70 miles away, Eaton County).
- Younkin sued in Genesee Circuit Court seeking a writ of mandamus to compel defendants (agency heads Zimmer and Hilfinger) to maintain the Genesee hearing site for his case.
- The trial court granted the writ; the Court of Appeals affirmed in a published, divided opinion.
- The Michigan Supreme Court, in a unanimous memorandum opinion, reversed the Court of Appeals and remanded with instructions to deny mandamus relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandamus required agency to hold hearing in the county where injury occurred | Younkin: "locality where the injury occurred" mandates a hearing in Genesee County | Zimmer/Hilfinger: "locality" can mean a district/region; hearings may be held at designated district offices (e.g., Dimondale) | Held: "Locality" reasonably read as district/region; no clear legal right to county-specific hearing; mandamus improper |
| Whether agency interpretation of statute merits deference | Younkin: agency misinterprets statutory text to avoid county hearings | Agency: interpretation entitled to respectful consideration; consistent with statute and administrative assignment of 11 districts | Held: agency interpretation persuasive and not in conflict with legislative intent |
| Whether statute requires a hearing site in every county | Younkin: statutory language implies county-level hearings where injury occurred | Agency: statute does not require per-county sites; districts may cover multiple counties | Held: statute does not require a hearing site in each county |
| Whether a district hearing 70 miles away is unreasonably inconvenient | Younkin: Dimondale is unreasonably inconvenient for plaintiff and witnesses | Agency: hearings must be convenient but need not be at the exact accident spot; district site is permissible | Held: inconvenience alone is not unreasonable; Dimondale within the proper district is acceptable |
Key Cases Cited
- In re MCI Telecom Complaint, 460 Mich 396 (agency deference and mandamus review framework)
- In re Complaint of Rovas Against SBC Mich, 482 Mich 90 (agency statutory interpretation entitled to respectful consideration)
- Crane v Leonard, Crossette & Riley, 214 Mich 218 (hearings should be convenient but need not be at the exact accident spot)
- Younkin v Zimmer, 304 Mich App 719 (Court of Appeals decision below)
- In re Wayne Co Prosecutor, 232 Mich App 482 (courts must not add statutory provisions the Legislature did not include)