Younkin v. Zimmer
304 Mich. App. 719
Mich. Ct. App.2014Background
- Younkin sustained an injury in Flint and timely claimed workers’ compensation; Flint office handled the claim initially.
- Zimmer announced consolidation: closing Flint office and transferring handling and hearings to Dimondale, aiming for hearings to start December 2012.
- Younkin sued in October 2012, arguing hearings must be held in the locality of injury under MCL 418.851 and that Dimondale is not a proper locality.
- Trial court held hearings, concluded ‘shall’ and ‘locality’ are mandatory and non-discretionary, and granted mandamus relief to hold Genesee County hearings in the locality of injury.
- Zimmer and Hilfinger appealed, arguing statute should be read for convenience and Crane v Leonard supports location flexibility; the appellate court affirmed the mandamus relief.
- Dissent would interpret locality more broadly as reasonably located districts; would reverse mandamus order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MCL 418.851 mandates hearings in the locality of injury | Younkin argued locality is the place of injury; Dimondale not proper. | Zimmer/Hilfinger argued Crane allows convenient-site interpretation; not strictly local. | Statute must be read literally; hearings must be in locality of injury. |
| Whether the writ of mandamus was proper to compel hearings in Genesee locality | Younkin has a clear legal right and defendants have a duty to hold hearings locally. | Writ should not compel all hearings or restrict discretion over resource allocation. | Writ appropriate to enforce the statutory duty to hold hearings in the locality. |
| Scope of the writ: whether it extends to all Genesee County claims or only to Younkin’s hearing | Writ should apply broadly to all Genesee County claims. | Writ should be limited to the individual claim; broader relief would overstep. | Writ extended to all Genesee County hearings according to the trial court; affirmed. |
| Effect of Crane v Leonard on interpretation of locality | Crane allows flexible venue when exact place is impracticable. | Crane does not authorize ignoring the locality requirement. | Crane does not permit ignoring statutory locality; Dimondale not proper locality for Genesee injuries. |
| Whether Dimondale qualifies as a locality under MCL 418.851 for Genesee claimants | Dimondale is within a reasonable distance and could serve as locality for hearings. | Locality must be the place where injury occurred; Dimondale is not sufficiently close. | Dimondale is not the locality; Flint/Genesee area is the proper locality. |
Key Cases Cited
- Crane v Leonard, 214 Mich 218; 183 NW 204 (1921) (Mich. 1921) (hearing location need not be literally the place of the accident; convenience is policy-driven)
- In re MCI Telecom Complaint, 460 Mich 396; 596 NW2d 164 (1999) (Mich. 1999) (mandamus to enforce a clear legal duty; statutory interpretation governs relief)
- In re Bradley Estate, 494 Mich 367; 835 NW2d 545 (2013) (Mich. 2013) (courts enforce statute as written when clearly unambiguous)
- Johnson v Recca, 492 Mich 169; 821 NW2d 520 (2012) (Mich. 2012) (statutory interpretation guiding proper construction)
- Teasel v Dep’t of Mental Health, 419 Mich 390; 355 NW2d 75 (1984) (Mich. 1984) (mandamus scope limits: cannot review discretionary decisions beyond clear duty)
- Petersen v Magna Corp, 484 Mich 300; 773 NW2d 564 (2009) (Mich. 2009) (harmonize statutory purpose with entire statutory scheme)