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196 Michigan opinions name it 2 courts 1951–2026 75 in the last five years
The cases below were cited by Michigan courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Cochrane v. Browngreen2 sentences2023Cochrane, 234 Mich App at 132 .2 “The purpose of a de novo hearing is for the trial court to render its own decision based on the evidence, independent of any prior ruling.” Sturgis v Sturgis, 302 Mich App 706, 708 ; 840 NW2d 408 (2013) (cleaned up); see also Marshall v Beal, 158 Mich App 582, 591 ; 405 NW2d 101 (1986) (explaining that when “a trial de novo is required, the circuit court is required to proceed as if no prior determination had been made and arrive at an independent decision”) (quotation marks and citation omitted). 2022See Cochrane v Brown, 234 Mich App 129, 131 ; 592 NW2d 123 (1999). -2- The trial court denied plaintiff’s request for a de novo hearing for two reasons. | 4 | 8 |
Dumm v. Brodbeckgreen2 sentences2022By court rule, the trial court may “conduct the judicial hearing by review of the record of the referee hearing, but the court must allow the parties to present live evidence at the judicial hearing.” MCR 3.215(F)(2); see also Dumm v Brodbeck, 276 Mich App 460, 465 ; 740 NW2d 751 (2007) (stating that the trial court is permitted to consider the referee’s recommendation “if it also allows the parties to present live evidence”). 2022By court rule, the trial court may “conduct the judicial hearing by review of the record of the referee hearing, but the court must allow the parties to present live evidence at the judicial hearing.” MCR 3.215(F)(2); see also Dumm v Brodbeck, 276 Mich App 460, 465 ; 740 NW2d 751 (2007) (stating that the trial court is permitted to consider the referee’s recommendation “if it also allows the parties to present live evidence”). | 3 | 4 |
People v. Atteburygreen2 sentences2013See People v Attebury, 463 Mich 662, 668 ; 624 NW2d 912 (2001) (“To the extent that a trial court’s ruling on a motion to suppress involves an interpretation of the law or the application of a constitutional standard to uncontested facts, our review is de novo.”). 2013See People v Attebury, 463 Mich 662, 668 ; 624 NW2d 912 (2001) (“To the extent that a trial court’s ruling on a motion to suppress involves an interpretation of the law or the application of a constitutional standard to uncontested facts, our review is de novo.”). | 3 | 3 |
Sturgis v. Sturgisgreen2 sentences2023Cochrane, 234 Mich App at 132 .2 “The purpose of a de novo hearing is for the trial court to render its own decision based on the evidence, independent of any prior ruling.” Sturgis v Sturgis, 302 Mich App 706, 708 ; 840 NW2d 408 (2013) (cleaned up); see also Marshall v Beal, 158 Mich App 582, 591 ; 405 NW2d 101 (1986) (explaining that when “a trial de novo is required, the circuit court is required to proceed as if no prior determination had been made and arrive at an independent decision”) (quotation marks and citation omitted). 2023Cochrane, 234 Mich App at 132 .2 “The purpose of a de novo hearing is for the trial court to render its own decision based on the evidence, independent of any prior ruling.” Sturgis v Sturgis, 302 Mich App 706, 708 ; 840 NW2d 408 (2013) (cleaned up); see also Marshall v Beal, 158 Mich App 582, 591 ; 405 NW2d 101 (1986) (explaining that when “a trial de novo is required, the circuit court is required to proceed as if no prior determination had been made and arrive at an independent decision”) (quotation marks and citation omitted). | 2 | 4 |
Thomas Township v. John Sexton Corp.green2 sentences2026See Thomas Twp v John Sexton Corp of Mich, 173 Mich App 507, 511; 434 NW2d 644 (1988) (concluding that an agency’s MEPA determinations were reviewed de novo on appeal). 18 In summary, interpreting MCL 324.1705(2) to provide for de novo review of administrative agencies’ MEPA determinations is “the meaning that makes the most sense were conducted by an ALJ. 2026See Thomas Twp v John Sexton Corp of Mich, 173 Mich App 507, 511; 434 NW2d 644 (1988) (concluding that an agency’s MEPA determinations were reviewed de novo on appeal). 18 In summary, interpreting MCL 324.1705(2) to provide for de novo review of administrative agencies’ MEPA determinations is “the meaning that makes the most sense were conducted by an ALJ. | 2 | 2 |
Adora Wilmore-Moody v. Mohammed Zakirgreen2 sentences2025See Wilmore-Moody, 511 Mich at 83, 85. 2025See Wilmore-Moody, 511 Mich at 83, 85. | 2 | 2 |
| Rivette v. Rose-Molinagreen | 2 | 2 |
| People v. Nelsongreen | 2 | 2 |
Beason v. Beasongreen2 sentences1993In addition to the de novo standard of review, as limited by the statute, this Court is also obligated to review divorce cases in accordance with Beason v Beason, 435 Mich 791, 798 ; 460 NW2d 207 (1990). 1993In addition to the de novo standard of review, as limited by the statute, this Court is also obligated to review divorce cases in accordance with Beason v Beason, 435 Mich 791, 798 ; 460 NW2d 207 (1990). | 1 | 6 |
Marshall v. Bealgreen2 sentences2024When a de novo hearing on a referee’s recommendations is properly requested, MCL 552.507(4) requires the trial court to “conduct a hearing as if no friend of the court hearing had been conducted previously and to arrive at an independent conclusion.” Marshall v Beal, 158 Mich App 582, 591 ; 405 NW2d 101 (1986). 2024When a de novo hearing on a referee’s recommendations is properly requested, MCL 552.507(4) requires the trial court to “conduct a hearing as if no friend of the court hearing had been conducted previously and to arrive at an independent conclusion.” Marshall v Beal, 158 Mich App 582, 591 ; 405 NW2d 101 (1986). | 1 | 3 |
Pierron v. Pierrongreen2 sentences2023STANDARD OF REVIEW To expedite the resolution of a child custody dispute by prompt and final adjudication, all orders and judgments of the circuit court shall be affirmed on appeal unless the trial judge made findings of fact against the great weight of evidence or committed a palpable abuse of discretion or a clear legal error on a major issue. [MCL 722.28; see also Pierron v Pierron, 486 Mich 81, 85 ; 782 NW2d 480 (2010).] Whether the trial court conducted a proper de novo hearing in response to a party’s objection to a referee’s recommendation is a question of law reviewed de novo. 2023STANDARD OF REVIEW To expedite the resolution of a child custody dispute by prompt and final adjudication, all orders and judgments of the circuit court shall be affirmed on appeal unless the trial judge made findings of fact against the great weight of evidence or committed a palpable abuse of discretion or a clear legal error on a major issue. [MCL 722.28; see also Pierron v Pierron, 486 Mich 81, 85 ; 782 NW2d 480 (2010).] Whether the trial court conducted a proper de novo hearing in response to a party’s objection to a referee’s recommendation is a question of law reviewed de novo. | 1 | 3 |
Guiles v. University of Michigan Board of Regentsgreen2 sentences2005Essentially, the Court, relying on Firestone Tire & Rubber Co v Bruch, 489 US 101, 115 ; 109 S Ct 948 ; 103 L Ed 2d 80 (1989), concluded that a de novo standard of review applied in cases involving the denial of benefits unless “the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Guiles, supra at 44, 46-47 . 2004Instead, according to Guiles, supra at 43 , a de novo standard of review applied. | 1 | 3 |
Firestone Tire & Rubber Co. v. Bruchgreen2 sentences2005Essentially, the Court, relying on Firestone Tire & Rubber Co v Bruch, 489 US 101, 115 ; 109 S Ct 948 ; 103 L Ed 2d 80 (1989), concluded that a de novo standard of review applied in cases involving the denial of benefits unless “the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Guiles, supra at 44, 46-47 . 2005Essentially, the Court, relying on Firestone Tire & Rubber Co v Bruch, 489 US 101, 115 ; 109 S Ct 948 ; 103 L Ed 2d 80 (1989), concluded that a de novo standard of review applied in cases involving the denial of benefits unless “the benefit plan gives the administrator or fiduciary discretionary authority to determine eligibility for benefits or to construe the terms of the plan.” Guiles, supra at 44, 46-47 . | 1 | 3 |
Rovas v. SBC Michigangreen2 sentences2026MCL 324.1705(2) requires, “as a minimum,” see Const 1963, art 6, § 28, that “a reviewing court must ensure that the finding is supported by record evidence,” but the court “does not conduct a new evidentiary hearing and reach its own factual conclusions, nor . . . subject the evidence to review de novo.” 17 MCL 324.1705(2) requires only a determination by the reviewing courts and nowhere indicates that a de novo standard should apply. 18 16 Merriam-Webster.com Dictionary, determine (accessed November 13, 2025). 17 In re Complaint of Rovas Against SBC Mich, 482 Mich 90, 101; 754 NW2d 259 (2008) 2026MCL 324.1705(2) requires, “as a minimum,” see Const 1963, art 6, § 28, that “a reviewing court must ensure that the finding is supported by record evidence,” but the court “does not conduct a new evidentiary hearing and reach its own factual conclusions, nor . . . subject the evidence to review de novo.” 17 MCL 324.1705(2) requires only a determination by the reviewing courts and nowhere indicates that a de novo standard should apply. 18 16 Merriam-Webster.com Dictionary, determine <https://www.meriam- webster.com/dictionary/determine> (accessed November 13, 2025). 17 In re Complaint of Rovas | 1 | 2 |
| Mudel v. Great Atlantic & Pacific Tea Co.green | 1 | 2 |
| People v. Goforthgreen | 1 | 2 |
| Burkey v. Burkeygreen | 1 | 2 |
| People v. Whitegreen | 1 | 1 |
| Rachel Anne Butters v. Patrick Lee Buttersgreen | 1 | 1 |
| People v. Sinclairgreen | 1 | 1 |
| People v. Jamiesongreen | 1 | 1 |
| People v. Auergreen | 1 | 1 |
| People v. Turnergreen | 1 | 1 |
| Van Buren Charter Twp. v. Visteon Corp.green | 1 | 1 |
| Reitmeyer v. Schultz Equipment & Parts Co, Incgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
DiBenedetto v. West Shore Hospital
green
2 sentences2015We review de novo “questions of law involved in any final order of the [commission].” DiBenedetto v West Shore Hosp, 461 Mich 394, 401 ; 605 NW2d 300 (2000). “[A] decision of the [commission] is subject to reversal if it is based on erroneous legal reasoning or the wrong legal framework.” Id. at 401-402 . [5] In addition, “[t]his Court reviews a . .. decision to admit evidence for an abuse of discretion; however, when the . .. decision involves a preliminary question of law, *307 such as whether a statute precludes the admission of evidence, a de novo standard of review is employed.” Detroit v 2015We review de novo “questions of law involved in any final order of the [commission].” DiBenedetto v West Shore Hosp, 461 Mich 394, 401 ; 605 NW2d 300 (2000). “[A] decision of the [commission] is subject to reversal if it is based on erroneous legal reasoning or the wrong legal framework.” Id. at 401-402 . [5] In addition, “[t]his Court reviews a . .. decision to admit evidence for an abuse of discretion; however, when the . .. decision involves a preliminary question of law, *307 such as whether a statute precludes the admission of evidence, a de novo standard of review is employed.” Detroit v | 8 | 2000–2023 |
City of Detroit v. DETROIT PLAZA LTD. PARTNERSHIP
green
2 sentences2023STANDARD OF REVIEW We “review[] a trial court’s decision to admit evidence for an abuse of discretion; however, when the trial court’s decision involves a preliminary question of law, such as whether a statute precludes the admission of evidence, a de novo standard of review is employed.” Detroit v Detroit Plaza Ltd Partnership, 273 Mich App 260, 275-276 ; 730 NW2d 523 (2006). 2023STANDARD OF REVIEW We “review[] a trial court’s decision to admit evidence for an abuse of discretion; however, when the trial court’s decision involves a preliminary question of law, such as whether a statute precludes the admission of evidence, a de novo standard of review is employed.” Detroit v Detroit Plaza Ltd Partnership, 273 Mich App 260, 275-276 ; 730 NW2d 523 (2006). | 5 | 2015–2023 |
Washington v. Washington
green
2 sentences2022Washington v Washington, 283 Mich App 667, 671 ; 770 NW2d 908 (2009) (citation omitted). 2022Washington v Washington, 283 Mich App 667, 671 ; 770 NW2d 908 (2009) (citation omitted). | 5 | 2021–2022 |
Federated Publications, Inc v. City of Lansing
red
2 sentences2005Our Supreme Court has held that “the application of exemptions requiring legal determinations are reviewed under a de novo standard, while application of exemptions requiring determinations of a discretionary nature .. . are reviewed under a clearly erroneous standard.” Federated Publications, Inc v City of Lansing, 467 Mich 98, 101 ; 649 NW2d 383 (2002). 2004Our Supreme Court has held that “the application of exemptions [under the FOIA] requiring legal determinations are reviewed under a de novo standard, while application of exemptions requiring determinations of a discretionary nature . . . are reviewed under a clearly erroneous standard.” Federated Publications, Inc v Lansing, 467 Mich 98, 101 ; 649 NW2d 383 (2002). | 5 | 2004–2016 |
Turcheck v. Amerifund Financial, Inc
green
2 sentences2026Likewise, “a trial court’s dismissal of an action pursuant to a contractual forum-selection clause is properly reviewed on appeal under a de novo standard.” Turcheck v Amerifund Fin, Inc, 272 Mich App 341, 351 ; 725 NW2d 684 (2006). 2026Likewise, “a trial court’s dismissal of an action pursuant to a contractual forum-selection clause is properly reviewed on appeal under a de novo standard.” Turcheck v Amerifund Fin, Inc, 272 Mich App 341, 351 ; 725 NW2d 684 (2006). | 4 | 2020–2026 |
People of Michigan v. Jarviz James Brown
green
2 sentences2025We generally review “constitutional claims under a de novo standard.” People v Brown, 339 Mich App 411 , 419; 984 NW2d 486 (2021). 2025We generally review “constitutional claims under a de novo standard.” People v Brown, 339 Mich App 411 , 419; 984 NW2d 486 (2021). | 4 | 2024–2025 |
Kimberly Marie Marik v. Peter Brian Marik
green
2 sentences2022Marik v Marik, 325 Mich App 353, 363-364 ; 925 NW2d 885 (2018). 2022Marik v Marik, 325 Mich App 353, 363-364 ; 925 NW2d 885 (2018). | 4 | 2022–2022 |
People v. Harverson
green
2 sentences2020People v Harverson, 291 Mich App 171, 177 ; 804 NW2d 757 (2010). 2020People v Harverson, 291 Mich App 171, 177 ; 804 NW2d 757 (2010). | 4 | 2018–2020 |
People v. Williams
green
2 sentences2026This inquiry involves “a mixed question of fact and law” and, therefore, “is subject to both a clear error and a de novo standard of review.” Id. 2025When evaluating whether joinder of two cases is permissible, the trial court must first “find the relevant facts and then must decide whether those facts constitute ‘related’ offenses for which joinder is appropriate,” which involves “a mixed question of fact and law” and, therefore, “is subject to both a clear error and a de novo standard of review.” People v Williams, 483 Mich 226, 231 ; 769 NW2d 605 (2009). | 3 | 2015–2026 |
Barclay v. Crown Building & Development, Inc.
green
2 sentences2026Barclay v Crown Bldg & Dev, Inc, 241 Mich App 639, 642 ; 617 NW2d 373 (2000). 2026Barclay v Crown Bldg & Dev, Inc, 241 Mich App 639, 642 ; 617 NW2d 373 (2000). | 3 | 2023–2026 |
In Re Contempt of ACIA
green
2 sentences2022Washington v Washington, 283 Mich App 667, 671 ; 770 NW2d 908 (2009), citing In re Contempt of Auto Club Ins Ass’n, 243 Mich App 697 , 714 n 33; 624 NW2d 443 (2000). 2021Washington v Washington, 283 Mich App 667, 671 ; 770 NW2d 908 (2009), citing In re Contempt of Auto Club Ins Ass’n, 243 Mich App 697 , 714 n 33; 624 NW2d 443 (2000). | 3 | 2021–2022 |
Webb v. Holzheuer
neutral
2 sentences2022State Farm Fire & Casualty Co v Corby Energy Servs, Inc, 271 Mich App 480, 483 ; 722 NW2d 906 (2006); Webb v Holzheuer, 259 Mich App 389, 391 ; 674 NW2d 395 (2003). 2022State Farm Fire & Casualty Co v Corby Energy Servs, Inc, 271 Mich App 480, 483 ; 722 NW2d 906 (2006); Webb v Holzheuer, 259 Mich App 389, 391 ; 674 NW2d 395 (2003). | 3 | 2021–2022 |
State Farm Fire & Casualty Co. v. Corby Energy Services, Inc.
green
2 sentences2022State Farm Fire & Casualty Co v Corby Energy Servs, Inc, 271 Mich App 480, 483 ; 722 NW2d 906 (2006); Webb v Holzheuer, 259 Mich App 389, 391 ; 674 NW2d 395 (2003). 2022State Farm Fire & Casualty Co v Corby Energy Servs, Inc, 271 Mich App 480, 483 ; 722 NW2d 906 (2006); Webb v Holzheuer, 259 Mich App 389, 391 ; 674 NW2d 395 (2003). | 3 | 2021–2022 |
Bruce Millar v. Construction Code Authority
green
2 sentences2022A de novo analysis “means that we review the issue independently, without any required deference to the trial court.” Millar v Constr Code Auth, 501 Mich 233, 237 ; 912 NW2d 521 (2018). 2022A de novo analysis “means that we review the issue independently, without any required deference to the trial court.” Millar v Constr Code Auth, 501 Mich 233, 237 ; 912 NW2d 521 (2018). | 3 | 2022–2022 |
People v. Trakhtenberg
green
2 sentences2018Id. 2018Id. | 3 | 2018–2018 |
In Re Complaint of Rovas Against Sbc
green
2 sentences2026MCL 324.1705(2) requires, “as a minimum,” see Const 1963, art 6, § 28, that “a reviewing court must ensure that the finding is supported by record evidence,” but the court “does not conduct a new evidentiary hearing and reach its own factual conclusions, nor . . . subject the evidence to review de novo.” 17 MCL 324.1705(2) requires only a determination by the reviewing courts and nowhere indicates that a de novo standard should apply. 18 16 Merriam-Webster.com Dictionary, determine (accessed November 13, 2025). 17 In re Complaint of Rovas Against SBC Mich, 482 Mich 90, 101; 754 NW2d 259 (2008) 2026MCL 324.1705(2) requires, “as a minimum,” see Const 1963, art 6, § 28, that “a reviewing court must ensure that the finding is supported by record evidence,” but the court “does not conduct a new evidentiary hearing and reach its own factual conclusions, nor . . . subject the evidence to review de novo.” 17 MCL 324.1705(2) requires only a determination by the reviewing courts and nowhere indicates that a de novo standard should apply. 18 16 Merriam-Webster.com Dictionary, determine <https://www.meriam- webster.com/dictionary/determine> (accessed November 13, 2025). 17 In re Complaint of Rovas | 2 | 2026–2026 |
People v. Gaines
green
2 sentences2026But “the ultimate decision on permissive joinder of related charges lies firmly within the discretion of trial courts.” People v Gaines, 306 Mich App 289, 304 ; 856 NW2d 222 (2014) (quotation marks and citation omitted). 2021Because this case presents a mixed question of fact and law, it is subject to both a clear error and a de novo standard of review. [Citations omitted.] However, the ultimate decision regarding permissive joinder of related cases “lies ‘firmly within the discretion of trial courts.’ ” People v Gaines, 306 Mich App 289, 304 ; 856 NW2d 222 (2014), quoting People v Breidenbach, 489 Mich 1, 14 ; 798 NW2d 738 (2011). | 2 | 2021–2026 |
Maiden v. Rozwood
green
2 sentences2025STANDARD OF REVIEW The proper interpretation of a contract and the legal effect of a contractual provision are questions of law that are reviewed de novo. 23 This Court also applies the de novo standard when reviewing the grant or denial of a motion for summary disposition. 24 Where, as here, a motion for summary disposition is brought under MCR 2.116(C)(7), the motion or opposition may be supported by documentary evidence as long as the substance or content of that evidence is admissible. 25 “The contents of the complaint are accepted as true unless contradicted by documentation submitted by 2025STANDARD OF REVIEW The proper interpretation of a contract and the legal effect of a contractual provision are questions of law that are reviewed de novo. 23 This Court also applies the de novo standard when reviewing the grant or denial of a motion for summary disposition. 24 Where, as here, a motion for summary disposition is brought under MCR 2.116(C)(7), the motion or opposition may be supported by documentary evidence as long as the substance or content of that evidence is admissible. 25 “The contents of the complaint are accepted as true unless contradicted by documentation submitted by | 2 | 2024–2025 |
| Karen Sue Lueck v. James Frederick Lueck green | 2 | 2023–2024 |
| Herald Co. v. Eastern Michigan University Board of Regents green | 2 | 2007–2023 |
| Fletcher v. Fletcher green | 2 | 1998–2023 |
| Harlan Vermilya v. Delta College Board of Trustees green | 2 | 2023–2023 |
| In re Proctor neutral | 2 | 2022–2022 |
| People v. Cole green | 2 | 2021–2021 |
| People of Michigan v. Tremel Anderson green | 2 | 2021–2021 |
| GMAC LLC v. Department of Treasury green | 2 | 2020–2020 |
| Vodvarka v. Grasmeyer green | 2 | 2018–2018 |
| Saffian v. Simmons green | 2 | 2017–2017 |
| Epps v. 4 Quarters Restoration LLC green | 2 | 2017–2017 |
| Heindlmeyer v. Ottawa County Concealed Weapons Licensing Board green | 2 | 2013–2014 |
| Loweke v. Ann Arbor Ceiling & Partition Co, LLC green | 2 | 2012–2013 |
| Spiek v. Department of Transportation green | 2 | 2003–2006 |
| Jerry Mahaffey v. Thomas Page, Warden green | 2 | 2005–2005 |
| Valdez v. People green | 2 | 2005–2005 |
| Tolbert v. Page green | 2 | 2005–2005 |
| Salve Regina College v. Russell green | 2 | 2005–2005 |
| Bradley v. Saranac Community Schools Board of Education green | 2 | 2002–2002 |
| Lincoln v. General Motors Corp. green | 2 | 2002–2002 |
| Herald Co. v. City of Bay City green | 2 | 2002–2002 |
| RAPISTAN CORPORATION v. Michaels green | 2 | 1996–1997 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.