second step analysis (Michigan) · Go Syfert
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second step analysis in Michigan

20 Michigan opinions name it 2 courts 1975–2026 2 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.

Followed or applied (5)

CaseFollowedCited
Johnson v. City of Pontiacgreen
mich · 1936 · cited in 2 Michigan opinions naming this issue, 2001–2001
2 sentences

2001The statute at issue contains the duty element of these principles; namely, the duty of a municipality to “maintain” the sidewalk “in reasonable repair so that it is reasonably safe and convenient for public travel.” MCL 691.1402(1). 8 See Johnson v Pontiac, 276 Mich 103, 105 ; 267 NW 795 (1936), explaining that “[t]he liability of cities for this class of cases is statutory . . . and it is the duty of defendant to keep its sidewalk in repair.” Concepts such as the “natural accumulation” doctrine, see below, are pertinent to this second step of the analysis.

2001The statute at issue contains the duty element of these principles; namely, the duty of a municipality to “maintain” the sidewalk “in reasonable repair so that it is reasonably safe and convenient for public travel.” MCL 691.1402(1). 8 See Johnson v Pontiac, 276 Mich 103, 105 ; 267 NW 795 (1936), explaining that “[t]he liability of cities for this class of cases is statutory . . . and it is the duty of defendant to keep its sidewalk in repair.” Concepts such as the “natural accumulation” doctrine, see below, are pertinent to this second step of the analysis.

22
People v. Knightgreen
mich · 2005 · cited in 4 Michigan opinions naming this issue, 2014–2016
2 sentences

2016Knight, 473 Mich at 343 .

2016Knight, 473 Mich at 343 .

14
Luckow Estate v. Luckowgreen
michctapp · 2011 · cited in 1 Michigan opinions naming this issue, 2025–2025
1 sentence

2025See Luckow, 291 Mich App at 424 .

11
Hudson v. United Statesgreen
scotus · 1997 · cited in 1 Michigan opinions naming this issue, 2007–2007
2 sentences

2007However, even if the Legislature intended a fee to be a civil penalty, with regard to the second step of the analysis, Hudson stated that a seemingly civil penalty may be “ ‘so punitive either in purpose or effect,’ as to ‘transfor[m] what was clearly intended as a civil remedy into a criminal penalty.’ ” Hudson, supra at 99 (citations omitted).

2007However, even if the Legislature intended a fee to be a civil penalty, with regard to the second step of the analysis, Hudson stated that a seemingly civil penalty may be "`so punitive either in purpose or effect,' as to `transfor[m] what was clearly intended as a civil remedy into a criminal penalty.'" Hudson, supra at 99 , 118 S.Ct. 488 (citations omitted).

11
Canon v. Thumudogreen
mich · 1988 · cited in 1 Michigan opinions naming this issue, 2001–2001
2 sentences

2001See Johnson, supra, stating that a plaintiff cannot recover if an injury is due “solely to the presence of ice or snow” (emphasis added). 8 “Courts should take care not to confuse their separate inquiries into [governmental] immunity and negligence.” Canon v Thumudo, 430 Mich 326, 335 ; 422 NW2d 688 (1988). 8 IV.

2001See Johnson, supra, stating that a plaintiff cannot recover if an injury is due “solely to the presence of ice or snow” (emphasis added). 8 “Courts should take care not to confuse their separate inquiries into [governmental] immunity and negligence.” Canon v Thumudo, 430 Mich 326, 335 ; 422 NW2d 688 (1988). 8 IV.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Kreiner v. Fischer red
mich · 2004
2 sentences

2009FISHER’S ABILITY TO LEAD HIS NORMAL LIFE When a court determines the nature and extent of a plaintiffs injuries as a matter of law, it must then proceed to the second step in the analysis and determine whether “an ‘important body function’ of the plaintiff has been impaired.” Kreiner, 471 Mich at 132 .

2009FISHER'S ABILITY TO LEAD HIS NORMAL LIFE When a court determines the nature and extent of a plaintiff's injuries as a matter of law, it must then proceed to the second step in the analysis and determine whether "an `important body function' of the plaintiff has been impaired." Kreiner, *476 471 Mich. at 132 , 683 N.W.2d 611 .

32005–2009
People v. Gray green
mich · 1998
2 sentences

2018The second step in our analysis is to determine whether the victim had an independent basis to identify the defendant in court.” Id. at 114-115 .

2018The second step in our analysis is to determine whether the victim had an independent basis to identify the defendant in court.” Id. at 114-115 .

22018–2018
Evening News Ass'n v. City of Troy green
mich · 1983
1 sentence

2026Id.

12026–2026
McKenzie v. Auto Club Insurance Ass'n green
mich · 1998
1 sentence

2015Regarding the second step of the test, whether the injury arose out of the ownership, operation, maintenance, or use of the parked motor vehicle as a motor vehicle, the Court explained that “the Legislature intended coverage of injuries resulting from the use of motor vehicles when closely related to their transportational function and only when engaged in that function.” Id. at 220 .

12015–2015
Haliw v. City of Sterling Heights green
mich · 2001
1 sentence

2007Haliw, supra at 305 .

12007–2007
Rice v. Auto Club Ins. Ass'n green
michctapp · 2002
2 sentences

2006With regard to the second step in the analysis under § 3105(1), Rice, supra at 33 , injuries arising out of contact with parked vehicles are generally not covered by the no-fault act.

2006With regard to the second step in the analysis under § 3105(1), Rice, supra at 33 , 651 N.W.2d 188 , injuries arising out of contact with parked vehicles are generally not covered by the no-fault act.

12006–2006
Federated Publications, Inc. v. Board of Trustees green
michctapp · 1997
2 sentences

1998“Meeting” is defined in the OMA as “the convening of a public body at which a quorum is present for the purpose of deliberating toward or rendering a decision on a public policy.” MCL 15.262(b); MSA 4.1800(12)(b); Federated Publications, Inc v Michigan State Univ Bd of Trustees, 221 Mich App 103, 116 ; 561 NW2d 433 (1997).

1998“Meeting” is defined in the OMA as “the convening of a public body at which a quorum is present for the purpose of deliberating toward or rendering a decision on a public policy.” MCL 15.262(b); MSA 4.1800(12)(b); Federated Publications, Inc v Michigan State Univ Bd of Trustees, 221 Mich App 103, 116 ; 561 NW2d 433 (1997).

11998–1998
Neil v. Biggers green
scotus · 1972
2 sentences

1998The second step in our analysis is to determine whether the victim had *115 an independent basis to identify the defendant in court. 9 As we explained in Anderson, 389 Mich 169 : If there was no counsel at the pretrial identification or if the procedures were unnecessarily suggestive or conducive to irreparable misidentification, then before an in-court identification may be received in evidence, the trial court must hold an evidentiary hearing out of the presence of the jury at which the people must show by clear and convincing evidence that the in-court identification has a basis independent

1998The second step in our analysis is to determine whether the victim had *115 an independent basis to identify the defendant in court. 9 As we explained in Anderson, 389 Mich 169 : If there was no counsel at the pretrial identification or if the procedures were unnecessarily suggestive or conducive to irreparable misidentification, then before an in-court identification may be received in evidence, the trial court must hold an evidentiary hearing out of the presence of the jury at which the people must show by clear and convincing evidence that the in-court identification has a basis independent

11998–1998
People v. Shaw green
michctapp · 1968
2 sentences

1975People v Shaw, 9 Mich App 558, 566 ; 157 NW2d 811 (1968), People v DerMartzex, supra, at 413.

1975People v Shaw, 9 Mich App 558, 566 ; 157 NW2d 811 (1968), People v DerMartzex, supra, at 413.

11975–1975

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 750.227b (4) MI § Mich. Comp. Laws § 500.3135 (3) MI § Mich. Comp. Laws § 691.1401 (3) MI § Mich. Comp. Laws § 691.1402 (3) MI § Mich. Comp. Laws § 691.1407 (3)

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.

Where else courts name it

TX 253 (1984–2026) CA 185 (1964–2026) OH 96 (1984–2025) IL 95 (1984–2026) IN 76 (1989–2025) IA 58 (1988–2026) MO 53 (1988–2019) OR 44 (1985–2026) KS 43 (1994–2026) WI 34 (1988–2026) NM 33 (1993–2026) WA 31 (1995–2025) PA 25 (1981–2026) NJ 24 (1983–2026) GA 23 (1985–2026) TN 23 (2001–2020) RI 21 (1983–2021) MI 20 (1975–2026) CT 20 (1985–2023) ID 20 (1993–2026) MN 18 (1988–2026) NY 17 (1988–2025) NC 15 (1986–2022) LA 14 (1991–2017) FL 14 (1999–2021) CO 14 (1989–2025) NV 11 (2012–2024) DE 11 (1983–2026) KY 11 (2010–2025) DC 11 (1984–2026) ME 11 (1981–2025) SC 10 (1990–2017) MD 9 (1993–2025) NE 9 (2015–2019) MS 9 (2007–2024) UT 9 (1991–2026) VT 8 (1990–2025) NH 8 (1985–2021) AR 7 (2018–2025) MA 7 (1981–2024) WY 7 (2005–2025) AK 5 (2019–2025) WV 5 (1989–2017) SD 4 (1985–2018) ND 4 (2002–2016) MT 4 (2003–2025) AL 4 (1994–2016) VI 4 (2012–2024) VA 4 (1992–2025) HI 3 (2002–2015) OK 2 (1991–2011)

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.

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