147 Michigan opinions name it 2 courts 1959–2026 13 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 |
|---|---|---|
Phillips v. Mirac, Incgreen2 sentences2023See Phillips v Mirac, Inc, 470 Mich 415, 434 ; 685 NW2d 174 (2004). 10 These also are findings of fact that the trial court made, which appellant does not challenge on appeal. -10- “The rational basis test considers whether the classification itself is rationally related to a legitimate governmental interest.” Id. (quotation marks and citations omitted). 2023See Phillips v Mirac, Inc, 470 Mich 415, 434 ; 685 NW2d 174 (2004). 10 These also are findings of fact that the trial court made, which appellant does not challenge on appeal. -10- “The rational basis test considers whether the classification itself is rationally related to a legitimate governmental interest.” Id. (quotation marks and citations omitted). | 3 | 8 |
Bostic v. Schaefergreen2 sentences2018See Bostic v. Schaefer , 760 F.3d 352 , 397 (C.A. 4, 2014) ( Niemeyer , J., dissenting), and cases cited therein. 2018See Bostic v Schaefer, 760 F3d 352, 397 (CA 4, 2014) (NIEMEYER, J., dissenting), and cases cited therein. | 3 | 3 |
Shepherd Montessori Center Milan v. Ann Arbor Charter Townshipgreen2 sentences2025“The general rule is that legislation that treats similarly situated groups disparately is presumed valid and will be sustained if it passes the rational basis standard of review[.]” Id. at 318 . “[A] classification will stand unless it is shown to be ‘essentially arbitrary.’ ” Wysocki, 248 Mich App at 354 . 2018Further, even employing the more deferential of standards,3 the rational basis standard of review, the classification that MCL 722.22(i) makes on the basis of sexual orientation must be “rationally related to a legitimate state interest.” Shepherd Montessori Ctr Milan, 486 Mich at 318-319 . | 2 | 7 |
Manistee Bank & Trust Co. v. McGowangreen2 sentences1999Under the traditional or rational basis test, a classification will stand unless it is shown to be "`essentially arbitrary.'" Id., quoting Lindsley, supra . 1988Petitioners first claim that the probate court erred by applying the traditional rational basis test rather than what petitioners refer to as the "means scrutiny” test derived from Manistee Bank & Trust Co v McGowan, 394 Mich 655 ; 232 NW2d 636 (1975), and Alexander v Detroit, 392 Mich 30 ; 219 NW2d 41 (1974). | 2 | 7 |
Wysocki v. Kivigreen2 sentences2025“The general rule is that legislation that treats similarly situated groups disparately is presumed valid and will be sustained if it passes the rational basis standard of review[.]” Id. at 318 . “[A] classification will stand unless it is shown to be ‘essentially arbitrary.’ ” Wysocki, 248 Mich App at 354 . 2020“In Michigan, courts have applied the rational basis test principally to economic and social legislation.” Wysocki, 248 Mich App at 354 . | 2 | 4 |
| United States v. Carltongreen | 2 | 2 |
| Trimble v. Gordongreen | 2 | 2 |
Shavers v. Attorney Generalgreen2 sentences2023Relying on Shavers, 402 Mich at 615 , the majority held that Eisenhower Center’s claims could not be resolved at this early stage of the proceedings, even under a rational basis standard of review, given the alleged lack of an adequate record. 2023Relying on Shavers, 402 Mich at 615 , the majority held that Eisenhower Center’s claims could not be resolved at this early stage of the proceedings, even under a rational basis standard of review, given the alleged lack of an adequate record. | 1 | 9 |
People v. Sleetgreen2 sentences2024Dobbs v Jackson Women’s Health Org, 597 US 215, 237-238, 300 ; 142 S Ct 2228 ; 213 L Ed 2d 545 (2022); Konopka, 309 Mich App at 367 ; People v Sleet, 193 Mich App 604, 605-606 ; 484 NW2d 757 (1992). 2024Dobbs v Jackson Women’s Health Org, 597 US 215, 237-238, 300 ; 142 S Ct 2228 ; 213 L Ed 2d 545 (2022); Konopka, 309 Mich App at 367 ; People v Sleet, 193 Mich App 604, 605-606 ; 484 NW2d 757 (1992). | 1 | 7 |
Smith v. Employment Security Commissiongreen2 sentences1999Under the traditional or rational basis test, a classification will stand unless it is shown to be “ ‘essentially arbitrary.’ ” Id., quoting Lindsley, supra. Stated differently, one who attacks an enactment must show that it is “arbitrary and wholly unrelated in a rational way to the objective of the statute.” Smith v Employment Security Comm, 410 Mich 231, 271 ; 301 NW2d 285 (1981). 1999Under the traditional or rational basis test, a classification will stand unless it is shown to be “ ‘essentially arbitrary.’ ” Id., quoting Lindsley, supra. Stated differently, one who attacks an enactment must show that it is “arbitrary and wholly unrelated in a rational way to the objective of the statute.” Smith v Employment Security Comm, 410 Mich 231, 271 ; 301 NW2d 285 (1981). | 1 | 4 |
Frame v. Nehlsgreen2 sentences1999Rather, the Court had previously determined to use the rational basis test, id. at 174-175, 550 N.W.2d 739 , and made its comments about the classifications using legitimacy as a factor in response to the grandfather's assertion that heightened scrutiny must be used. 1999(Certainly, the Court again later in its opinion referred to its use of the rational basis test: "Because there is no fundamental right or suspect classification involved, a rational basis test is used." Id. at 189 , 550 N.W.2d 739 . | 1 | 4 |
Plyler v. Doegreen2 sentences2001Plyler v Doe, 457 US 202, 216-217 ; 102 S Ct 2382 ; 72 L Ed 2d 786 (1982); Conat, supra. Under the rational basis test, the legislation is presumed to be constitutional and the party challenging the statute has the burden of proving that the legislation is arbitrary and, thus, irrational. 2001Plyler v Doe, 457 US 202, 216-217 ; 102 S Ct 2382 ; 72 L Ed 2d 786 (1982); Conat, supra. Under the rational basis test, the legislation is presumed to be constitutional and the party challenging the statute has the burden of proving that the legislation is arbitrary and, thus, irrational. | 1 | 3 |
Bissell v. Kommareddigreen2 sentences1996See Bissell v Kommareddi, 202 Mich App 578 ; 509 NW2d 542 (1993). 1996See Bissell v Kommareddi, 202 Mich App 578 ; 509 NW2d 542 (1993). | 1 | 3 |
Gilson v. Department of Treasurygreen2 sentences2025“In order to perform an equal protection analysis, we must first determine which constitutional test applies, strict scrutiny or the rational basis test.” Gilson v Dep’t of Treasury, 215 Mich App 43, 50 ; 544 NW2d 673 (1996). 2025“In order to perform an equal protection analysis, we must first determine which constitutional test applies, strict scrutiny or the rational basis test.” Gilson v Dep’t of Treasury, 215 Mich App 43, 50 ; 544 NW2d 673 (1996). | 1 | 2 |
| Romer v. Evansgreen | 1 | 2 |
Ronald Loesel v. City of Frankenmuthgreen2 sentences2018Defendant must negate "every conceivable *107 reason for the government's actions" or show "that the actions were motivated by animus or ill-will." Loesel v. Frankenmuth , 692 F.3d 452 , 462 (C.A. 6, 2012) (cleaned up). 2015The second prong of the test, i.e., a rational basis inquiry, is demonstrated by “either by negativing every conceivable reason for the government’s actions or by demonstrating that the actions were motivated by animus or ill-will.” Loesel, 692 F3d at 462, 465 (quotation marks and citation omitted). | 1 | 2 |
| People v. Perlosgreen | 1 | 2 |
| Heinz v. Chicago Road Investment Co.green | 1 | 2 |
| O'Donnell v. State Farm Mutual Automobile Insurancegreen | 1 | 2 |
| Shavers v. Attorney Generalgreen | 1 | 2 |
| John Doe v. Gary Settlegreen | 1 | 1 |
| Flemming v. Nestorgreen | 1 | 1 |
| Kansas v. Hendricksgreen | 1 | 1 |
| Hudson v. United Statesgreen | 1 | 1 |
| United States v. Kebodeauxgreen | 1 | 1 |
| Dobbs v. Jackson Women's Health Organizationgreen | 1 | 1 |
| Kennedy v. Mendoza-Martinezgreen | 1 | 1 |
| Peter Nelson v. Town of Parisgreen | 1 | 1 |
| Armour v. City of Indianapolisgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| Trimble v. Gordongreen | 1 | 2 |
| Case | Cited | Years |
|---|---|---|
Doe v. Department of Social Services
green
2 sentences2023Stated differently, “legislation challenged on equal protection grounds is accorded a presumption of constitutionality, and it is reviewed by applying a rational basis standard.” Doe v Dep’t of Social Servs, 439 Mich 650, 662 ; 487 NW2d 166 (1992). 2023Stated differently, “legislation challenged on equal protection grounds is accorded a presumption of constitutionality, and it is reviewed by applying a rational basis standard.” Doe v Dep’t of Social Servs, 439 Mich 650, 662 ; 487 NW2d 166 (1992). | 10 | 1995–2023 |
Crego v. Coleman
green
2 sentences2011Therefore, under the rational-basis standard, “ ‘courts will uphold legislation as long as that legislation is rationally related to a legitimate government purpose.’ ” Phillips, 470 Mich at 433 , quoting Crego v Coleman, 463 Mich 248, 259 ; 615 NW2d 218 (2000). 2011Therefore, under the rational-basis standard, “ ‘courts will uphold legislation as long as that legislation is rationally related to a legitimate government purpose.’ ” Phillips, 470 Mich at 433 , quoting Crego v Coleman, 463 Mich 248, 259 ; 615 NW2d 218 (2000). | 8 | 2001–2024 |
People v. Pitts
green
2 sentences2025“Under the rational basis test, the legislation is presumed to be constitutional and the party challenging the statute has the burden of proving that the legislation is arbitrary and thus irrational.” People v Pitts, 222 Mich App 260, 273 ; 564 NW2d 93 (1997). 2025“Under the rational basis test, the legislation is presumed to be constitutional and the party challenging the statute has the burden of proving that the legislation is arbitrary and thus irrational.” People v Pitts, 222 Mich App 260, 273 ; 564 NW2d 93 (1997). | 6 | 1998–2025 |
Harvey v. State
green
2 sentences2022“Under rational-basis review, courts will uphold legislation as long as that legislation is rationally related to a legitimate government purpose.” Harvey v State, Dep't of Mgt and Budget, Bureau of Retirement Servs, 469 Mich 1, 7 ; 664 NW2d 767 (2003). 2022“Under rational-basis review, courts will uphold legislation as long as that legislation is rationally related to a legitimate government purpose.” Harvey v State, Dep't of Mgt and Budget, Bureau of Retirement Servs, 469 Mich 1, 7 ; 664 NW2d 767 (2003). | 6 | 2006–2022 |
Muskegon Area Rental Ass'n v. City of Muskegon
green
2 sentences2005The statute at issue is reviewed pursuant to the rational basis test. [4] A review pursuant to the rational basis standard does not examine "the wisdom, need, or appropriateness of the legislation." Muskegon Area Rental Ass'n v. City of Muskegon, 465 Mich. 456, 464 , 636 N.W.2d 751 (2001) (citation deleted). 2005The statute at issue is reviewed pursuant to the rational basis test. [4] A review pursuant to the rational basis standard does not examine "the wisdom, need, or appropriateness of the legislation." Muskegon Area Rental Ass'n v. City of Muskegon, 465 Mich. 456, 464 , 636 N.W.2d 751 (2001) (citation deleted). | 5 | 2005–2009 |
Neal v. Oakwood Hospital Corp.
green
2 sentences2007Id. 2007Id. | 5 | 2000–2007 |
Kyser v. Kasson Twp
green
2 sentences2018Kyser v. Kasson Twp. , 486 Mich. 514 , 522 n 2, 786 N.W.2d 543 (2010). 2018Kyser v. Kasson Twp. , 486 Mich. 514 , 522 n 2, 786 N.W.2d 543 (2010). | 4 | 2013–2018 |
Vargo v. Sauer
green
2 sentences2007Id. 2004Va rgo, supra, 457 Mich 60 . | 4 | 2000–2007 |
Stevenson v. Reese
green
2 sentences2004The rational basis test considers whether the “classification itself is rationally related to a legitimate governmental interest.” Id. 2004The rational basis test considers whether the "classification itself is rationally related to a legitimate governmental interest." Id. | 4 | 2001–2004 |
Alexander v. City of Detroit
green
2 sentences1988Petitioners first claim that the probate court erred by applying the traditional rational basis test rather than what petitioners refer to as the "means scrutiny” test derived from Manistee Bank & Trust Co v McGowan, 394 Mich 655 ; 232 NW2d 636 (1975), and Alexander v Detroit, 392 Mich 30 ; 219 NW2d 41 (1974). 1988Petitioners first claim that the probate court erred by applying the traditional rational basis test rather than what petitioners refer to as the "means scrutiny” test derived from Manistee Bank & Trust Co v McGowan, 394 Mich 655 ; 232 NW2d 636 (1975), and Alexander v Detroit, 392 Mich 30 ; 219 NW2d 41 (1974). | 4 | 1981–2001 |
Barrow v. City of Detroit Election Commission
green
2 sentences2024Andary, 512 Mich at 268; Barrow, 301 Mich App at 419-420 . 2024“Traditionally, the rational basis test applies where no suspect factors are present or where no fundamental right is implicated.” Barrow, 301 Mich App at 419 .3 Here, defendant concedes that no circumstances exist that would warrant heightened scrutiny and that his claim is subject to rational basis review. | 3 | 2020–2024 |
Houdek v. Centerville Township
green
2 sentences2023“Where the proponent of an equal protection argument is not a member of a protected class, or does not allege violation of a fundamental right, the equal protection claim is reviewed using the rational basis test.” Id. 2022“Where the proponent of an equal protection argument is not a member of a protected class, or does not allege violation of a fundamental right, the equal protection claim is reviewed using the rational basis test.” Houdek v Centreville Twp, 276 Mich App 568, 585-586 ; 741 NW2d 587 (2007). | 3 | 2020–2023 |
Zdrojewski v. Murphy
green
2 sentences2015Consequently, because no suspect class --based upon age, disability, race, or gender-- is being singled out and no fundamental right is being affected, we apply the rational basis test to determine whether the 1999 amendment violates equal protection.14 “Under the rational basis test, legislation is presumed to be constitutional and will survive review if the classification scheme is rationally related to a legitimate governmental purpose.” Zdrojewski, 254 Mich App at 80 . 2015Consequently, because no suspect class — based on age, disability, race, or gender — is being singled out and no fundamental right is being affected, we apply the rational basis test to determine whether the 1999 amendment violates equal protection. 14 “Under the rational basis test, legislation is presumed to be constitutional and will survive review if the classification scheme is rationally related to a legitimate governmental purpose.” Zdrojewski, 254 Mich App at 80 . | 3 | 2015–2015 |
Proctor v. White Lake Township Police Department
green
2 sentences2015Initially, the rational basis analysis in both cases was rather cursory, as Proctor, 248 Mich App at 469 , summarily concluded “that the Legislature’s FOIA exclusions singling out incarcerated prisoners rationally relate to the Legislature’s legitimate interest in conserving the scarce governmental resources squandered responding to frivolous FOIA requests by incarcerated prisoners.” The pertinent analysis in Morales was similarly short, as the opinion cited Proctor and concluded that “the exclusion of prisoners’ ability under MCL 791.234 to appeal parole denials is rationally related to the L 2015Initially, the rational-basis analysis in both cases was rather cursory, as Proctor, 248 Mich App at 469 , summarily concluded “that the Legislature’s FOIA exclusions singling out incarcerated prisoners rationally relate to the Legislature’s legitimate interest in conserving the scarce governmental resources squandered responding to frivolous FOIA requests by incarcerated prisoners.” The pertinent analysis in Morales was similarly short, as the opinion cited Proctor and concluded that “the exclusion of prisoners’ ability under MCL 791.234 to appeal parole denials is rationally related to the L | 3 | 2007–2015 |
People v. Idziak
green
2 sentences2015“Under the rational basis test, the challenged legislation ‘is presumed constitutional, and the party challenging it bears a heavy burden of rebutting that presumption.’ ” Parole of Hill, 298 Mich App at 421 , quoting People v Idziak, 484 Mich 549, 570 ; 773 NW2d 616 (2009). 2015“Under the rational basis test, the challenged legislation ‘is presumed constitutional, and the party challenging it bears a heavy burden of rebutting that presumption.’ ” Parole of Hill, 298 Mich App at 421 , quoting People v Idziak, 484 Mich 549, 570 ; 773 NW2d 616 (2009). | 3 | 2012–2015 |
Lindsley v. Natural Carbonic Gas Co.
green
2 sentences1999Under the traditional or rational basis test, a classification will stand unless it is shown to be “ ‘essentially arbitrary.’ ” Id., quoting Lindsley, supra. Stated differently, one who attacks an enactment must show that it is “arbitrary and wholly unrelated in a rational way to the objective of the statute.” Smith v Employment Security Comm, 410 Mich 231, 271 ; 301 NW2d 285 (1981). 1976The Court found that the legislation did not violate the Equal Protection Clause and reiterated the rationality test of Lindsley, supra: 7 "We turn then to examine this state classification under the rational-basis standard. | 3 | 1976–1999 |
In Re Contempt of Stone
green
2 sentences1987Consequently, the Court finds that the charter provision, which was adopted *556 pursuant to the Home Rule Cities Act, MCL 117.1 et seq. [MSA 5.2071 et seq.], does not conflict with or contravene the provisions of any general law of this state. [5] Plaintiff also urges this Court to find that the charter provision fails the rational basis test, the standard for traditional equal protection The rational basis test was described by this Court in In re Contempt of Stone, 154 Mich App 121, 128-129 ; 397 NW2d 244 (1986), lv den 426 Mich 854 (1986): The statute needs only a rational basis to be vali 1987Consequently, the Court finds that the charter provision, which was adopted *556 pursuant to the Home Rule Cities Act, MCL 117.1 et seq. [MSA 5.2071 et seq.], does not conflict with or contravene the provisions of any general law of this state. [5] Plaintiff also urges this Court to find that the charter provision fails the rational basis test, the standard for traditional equal protection The rational basis test was described by this Court in In re Contempt of Stone, 154 Mich App 121, 128-129 ; 397 NW2d 244 (1986), lv den 426 Mich 854 (1986): The statute needs only a rational basis to be vali | 3 | 1987–1987 |
| Zablocki v. Redhail green | 2 | 2011–2018 |
| Brinkley v. Brinkley green | 2 | 2014–2016 |
| In re Parole of Hill green | 2 | 2015–2015 |
| Morales v. Michigan Parole Bd. green | 2 | 2012–2015 |
| Vance v. Bradley green | 2 | 1995–2011 |
| Massachusetts Board of Retirement v. Murgia green | 2 | 1979–2011 |
| Heller v. Doe Ex Rel. Doe green | 2 | 2009–2009 |
| Morreale v. Department of Community Health neutral | 2 | 2007–2007 |
| Downriver Plaza Group v. Southgate green | 2 | 1996–2007 |
| Tig Premier Insur Co v. Dept of Treasury green | 2 | 2001–2007 |
| Yaldo v. North Pointe Insurance green | 2 | 1999–2007 |
| New York City Transit Authority v. Beazer green | 2 | 2006–2006 |
| Duke Power Co. v. Carolina Environmental Study Group, Inc. green | 2 | 2004–2006 |
| Phillips v. Mirac, Inc green | 2 | 2003–2004 |
| United States Department of Agriculture v. Moreno green | 2 | 2000–2004 |
| Padover v. Township of Farmington green | 2 | 2004–2004 |
| Goesaert v. Cleary green | 2 | 1986–2003 |
| McGowan v. Maryland green | 2 | 1983–2002 |
| Brittany Park Apartments v. Harrison Charter Township green | 2 | 1998–2001 |
| Clark v. Jeter green | 2 | 1999–2000 |
| Dandridge v. Williams green | 2 | 1984–1999 |
| McAvoy v. H B Sherman Co. green | 2 | 1985–1999 |
| City of St Louis v. Michigan Underground Storage Tank Financial Assurance Policy Board green | 2 | 1997–1998 |
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.