Plaintiffs appeal by leave granted the trial court’s grant of defendant’s summary-disposition motion under MCR 2.116(C)(7) and (C)(8). We affirm.
Plaintiffs contend that their right to equal protection was violated when the trial court applied a three-year period of limitation to their inverse-condemnation claim against defendant, when inverse-condemnation actions against entities other than the state are subject to at least a six-year limitation period. We disagree. This Court reviews de novo a trial court’s ruling on a party’s motion for summary disposition.
Spiek v Dep’t of Transportation,
An inverse-condemnation action is a claim ex contractu over which the Court of Claims has exclusive jurisdiction.
Lim v Dep’t of Transportation,
A statute of limitations is a procedural, not substantive, rule.
Forest v Parmalee,
In addition, plaintiffs failed to satisfy their burden of showing that the statutory classifications created by the different limitation periods (inverse-condemnation claims against state entities versus all other inverse-condemnation claims) lacked a rational basis. Forest, supra at 356. Where the classification is reasonably related to a legitimate state interest, there can be no equal-protection violation. Id. Case law repeatedly affirms the reasonable relationship between facilitating the state’s ability “to estimate with some degree of certainty the extent of their future financial obligations” and placing a limit on the time during which a plaintiff may bring action against the state. Forest, supra at 360.
Here, plaintiffs filed their complaint on November 27, 2000, more than three years after incurring the $54,900 loss for which they seek compensation from defendant. Therefore, plaintiffs’ claim was barred by the three-year limitation period governing actions over which the Court of Claims has jurisdiction. Despite its incorrect application of
Hart v Detroit,
Our disposition of plaintiffs’ appeal on this basis makes it unnecessary to review whether the trial court properly granted defendant’s C(8) motion.
Affirmed.
