Alderman v. Jc Dev. Communities, LLC, 780 N.W.2d 840 (Mich. 2010). · Go Syfert
Alderman v. Jc Dev. Communities, LLC, 780 N.W.2d 840 (Mich. 2010). Cases Citing This Book View Copy Cite
“the only employees exposed to the risk of electrocution were two to six employees of one subcontractor, including the plaintiff, and therefore there was not a high degree of risk to a significant number of workers.”
38 citation events (38 in the last 25 years) across 5 distinct courts.
Strongest positive: Matthew Belobradich v. Centennial Home Group LLC (michctapp, 2023-10-19)
Treatment trajectory · 2010 → 2026 · click a year to view as-of
2010 2018 2026
Top citers, strongest first. 7 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Matthew Belobradich v. Centennial Home Group LLC
Mich. Ct. App. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
the only employees exposed to the risk of electrocution were two to six employees of one subcontractor, including the plaintiff, and therefore there was not a high degree of risk to a significant number of workers.
discussed Cited as authority (rule) Nathan Swan v. Patrick O'Leary (2×) also: Cited "see, e.g."
Mich. Ct. App. · 2025 · confidence medium
Similarly, our Supreme Court, in Alderman v JC Dev Communities, LLC, 486 Mich 906, 906 (2010), held there -5- was not a high degree of risk to a significant number of workers because “[t]he only employees exposed to the risk . . . were two to six employees of one subcontractor, including the plaintiff[.]” In this case, only four people were shown to be near or on the platform when it was being improperly used: plaintiff, Bueby, and two other independent contractors in Bueby’s employ.
discussed Cited as authority (rule) Shareef El-Jamaly v. Kirco Manix Construction LLC (2×)
Mich. · 2024 · confidence medium
Placing ultimate responsibility on the general contractor for job safety in common work areas will, from a practical, economic standpoint, render it more likely that the various subcontractors being supervised by the general contractor will implement or that the general contractor will himself implement the necessary precautions and provide the necessary safety equipment in those areas. ‘[A]s a practical matter in many cases only the general contractor is in a position to coordinate work or provide expensive safety features that protect employees of many or all of the subcontractors. . . . […
discussed Cited as authority (rule) Estate of Joseph Daniel Velez Jr v. Richard Shafer (2×) also: Cited "see"
Mich. Ct. App. · 2020 · confidence medium
Alderman v JC Dev Communities, LLC, 486 Mich 906, 906 (2010).
discussed Cited as authority (rule) Michelle Richter v. American Aggregates Corporation (2×)
6th Cir. · 2013 · confidence medium
Communities, L.L.C., 486 Mich. 906 , 780 N.W.2d 840, 840 (2010), forecloses Richter’s argument.
examined Cited as authority (rule) Duncan v. State (3×)
Mich. Ct. App. · 2013 · confidence medium
Our Supreme Court later affirmed, albeit in result only, opining that solely on the basis of “plaintiffs’ pleadings in this case, it is premature to make a decision on the substantive issues.” Duncan, 486 Mich at 906.
discussed Cited "see" Shareef El-Jamaly v. Kirco Manix Construction LLC (2×)
Mich. Ct. App. · 2022 · signal: see · confidence high
See Alderman v JC Dev Communities, LLC, 486 Mich 906, 906 (2010) (defining the relevant danger as “the risk of electrocution from a subcontractor’s crane coming into contact with power lines above the construction site”).
Retrieving the full opinion text from the archive…
Randy ALDERMAN, Plaintiff-Appellee,
v.
J.C. DEVELOPMENT COMMUNITIES, L.L.C., Defendant-Appellant.
140051.
Michigan Supreme Court.
Apr 30, 2010.
780 N.W.2d 840

Order

On order of the Court, the application for leave to appeal the August 25, 2009 judgment of the Court of Appeals is considered and, pursuant to MCR 7.302(H)(1), in lieu of granting leave to appeal, we REVERSE the judgment of the Court of Appeals and we REINSTATE the Oakland Circuit Court's May 16, 2008 order granting summary disposition. The Court of Appeals erred by holding that the common-work-area doctrine applies to this case. The risk of injury at issue here was the risk of electrocution from a subcontractor's crane coming into contact with power lines above the construction site. The only employees exposed to the risk of electrocution were two to six employees of one subcontractor, including the plaintiff, and therefore there was not a high degree of risk to a significant number of workers. Ormsby v. Capital Welding, Inc., 471 Mich. 45, 684 N.W.2d 320 (2004).

MARILYN J. KELLY, C.J., and HATHAWAY, J., would deny leave to appeal.