continuing violation in Michigan

19 Michigan opinions name it 2 courts 1972–2024 1 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 (7)

Case	Followed	Cited
Garg v. MacOmb County Community Mental Health Servicesgreen mich · 2005 · cited in 2 Michigan opinions naming this issue, 2017–2017 2 sentences 2017See Garg, 472 Mich at 283-285 . -3- DEQ’s suit against BP was not an action in rem because BP has not been adjudged responsible for civil fines or criminal penalties. 2017See Garg, 472 Mich at 283-285 . -3- DEQ’s suit against BP was not an action in rem because BP has not been adjudged responsible for civil fines or criminal penalties.	2	2
Sumner v. Goodyear Tire & Rubber Co.red mich · 1986 · cited in 4 Michigan opinions naming this issue, 1995–2005 2 sentences 2003Dynamics 143 Land Sys., Inc., 212 Mich.App. 585, 587 , 538 N.W.2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in M.C.L. § 37.2202), citing Rasheed v. Chrysler Corp., 445 Mich. 109 , 517 N.W.2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 , 398 N.W.2d 368 (race-based harassment from supervisors as a continuing violation); Meek v. Michigan Bell Co., 193 Mich.App. 340, 342-343 , 483 N.W.2d 407 (1991) (sex-based and religion-based harassment from supervisors); see als 2003*Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F	1	4
People v. Monacogreen mich · 2006 · cited in 1 Michigan opinions naming this issue, 2006–2006 2 sentences 2006As I opined in my concurrence/dissent in People v Monaco, 474 Mich 48, 59-65 (2006), the majority incorrectly determined that felony nonsupport is not a continuing violation. 2006As I opined in my concurrence/dissent in People v. Monaco, 474 Mich. 48, 59-65 , 710 N.W.2d 46 (2006), the majority incorrectly determined that felony nonsupport is not a continuing violation.	1	1
Linda Jackson v. Quanex Corporationgreen ca6 · 1999 · cited in 1 Michigan opinions naming this issue, 2003–2003 2 sentences 2003Dynamics 143 Land Sys., Inc., 212 Mich.App. 585, 587 , 538 N.W.2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in M.C.L. § 37.2202), citing Rasheed v. Chrysler Corp., 445 Mich. 109 , 517 N.W.2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 , 398 N.W.2d 368 (race-based harassment from supervisors as a continuing violation); Meek v. Michigan Bell Co., 193 Mich.App. 340, 342-343 , 483 N.W.2d 407 (1991) (sex-based and religion-based harassment from supervisors); see als 2003*Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F	1	1
Paschke v. Retool Industriesgreen mich · 1994 · cited in 1 Michigan opinions naming this issue, 1999–1999 1 sentence 1999“The doctrine of judicial estoppel is to be *364 applied with caution.” Paschke, supra at 523 (Griffin, J., dissenting).	1	1
People v. Corbettgreen michctapp · 1980 · cited in 1 Michigan opinions naming this issue, 1981–1981 2 sentences 1981See People v Corbett, 97 Mich App 438 ; 296 NW2d 64 (1980). 1981See People v Corbett, 97 Mich App 438 ; 296 NW2d 64 (1980).	1	1
City of Gaylord v. Gaylord City Clerkgreen mich · 1966 · cited in 1 Michigan opinions naming this issue, 1972–1972 2 sentences 1972A. Constitutional Public Purpose We held in City of Gaylord v Gaylord City Clerk, 378 Mich 273, 294-295 (1966) that despite the absence of specified general limits on legislative power, and because the theme of public purpose runs through the constitution, the power of the Legislature and of government generally are limited "to such acts and such governmental powers as exhibit a public purpose.” Id, 295. 1972A. Constitutional Public Purpose We held in City of Gaylord v Gaylord City Clerk, 378 Mich 273, 294-295 (1966) that despite the absence of specified general limits on legislative power, and because the theme of public purpose runs through the constitution, the power of the *318 Legislature and of government generally are limited "to such acts and such governmental powers as exhibit a public purpose." Id, 295.	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (17)

Case	Cited	Years
People v. Westman green michctapp · 2004 2 sentences 2006Expanding on the ruling in Westman, supra, in which the Court held that a violation of MCL 750.165(1) constitutes a continuing crime, the panel held: [A] violation may be continuing under either the “amount owed theory” or the “time ordered theory.” Under the “amount owed theory,” the violation continues as long as an ordered support goes unpaid. 2004People v Westman, 262 Mich App 184 ; 685 NW2d 423 (2004).	3	2004–2006
United Air Lines, Inc. v. Evans green scotus · 1977 2 sentences 2005However, the United States Supreme Court held that merely demonstrating a "present effect to a past act of discrimination" is insufficient to create a continuing violation. 657 Id. at 558 , 97 S.Ct. 1885 . "[T]he emphasis should not be placed on mere continuity; the critical question is whether any present violation exists." Id. 2005However, the United States Supreme Court held that merely demonstrating a "present effect to a past act of discrimination" is insufficient to create a continuing violation. 657 Id. at 558 , 97 S.Ct. 1885 . "[T]he emphasis should not be placed on mere continuity; the critical question is whether any present violation exists." Id.	2	1986–2005
People v. Westman green michctapp · 2004 2 sentences 2004People v. Westman, 262 Mich.App. 184 , 685 N.W.2d 423 (2004). 2004People v Westman, 262 Mich App 184 ; 685 NW2d 423 (2004).	2	2004–2004
Stanley Trzebuckowski Lecue, Inc. v. City of Cleveland Lauren C. Moore green ca6 · 2003 1 sentence 2024And there is a “subtle difference between a continuing violation and a continuing effect of a prior violation.” Trzebuckowski, 319 F3d at 858 .	1	2024–2024
Quality Products and Concepts Co. v. Nagel Precision, Inc. green mich · 2003 2 sentences 2020In Quality Prod & Concepts Co v Nagel Precision, Inc, 469 Mich 362, 364-365 ; 666 NW2d 251 (2003), the Court explained: [P]arties to a contract are free to mutually waive or modify their contract notwithstanding a written modification or anti-waiver clause because of the freedom to contract. 2020In Quality Prod & Concepts Co v Nagel Precision, Inc, 469 Mich 362, 364-365 ; 666 NW2d 251 (2003), the Court explained: [P]arties to a contract are free to mutually waive or modify their contract notwithstanding a written modification or anti-waiver clause because of the freedom to contract.	1	2020–2020
Pohutski v. City of Allen Park green mich · 2002 2 sentences 2019The circuit court summarily dismissed Morley’s trespass-nuisance claim pursuant to MCR 2.116(C)(7), concluding that the township was immune from such claims pursuant to Pohutski v Allen Park, 465 Mich 675 ; 641 NW2d 219 (2002). 2019The circuit court summarily dismissed Morley’s trespass-nuisance claim pursuant to MCR 2.116(C)(7), concluding that the township was immune from such claims pursuant to Pohutski v Allen Park, 465 Mich 675 ; 641 NW2d 219 (2002).	1	2019–2019
Toussie v. United States red scotus · 1970 2 sentences 2006The Supreme Court gave us this guidance in Toussie : [A conclusion that a violation is a continuing violation should not be made] unless the explicit language of the substantive criminal statute compels such a conclusion, or the nature of the crime involved is such that Congress must assuredly have intended that it be treated as a continuing one. [ Id. at 115 , 90 S.Ct. 858 .] THE LEGISLATURE INTENDED A CONTINUING OFFENSE IN MCL 750.165(1) Whether a continuing violation exists is a matter of statutory interpretation. 2006The Supreme Court gave us this guidance in Toussie : [A conclusion that a violation is a continuing violation should not be made] unless the explicit language of the substantive criminal statute compels such a conclusion, or the nature of the crime involved is such that Congress must assuredly have intended that it be treated as a continuing one. [ Id. at 115 , 90 S.Ct. 858 .] THE LEGISLATURE INTENDED A CONTINUING OFFENSE IN MCL 750.165(1) Whether a continuing violation exists is a matter of statutory interpretation.	1	2006–2006
Meek v. Michigan Bell Telephone Co. green michctapp · 1992 2 sentences 2003Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F 2003Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F	1	2003–2003
Downey v. Charlevoix County Board green michctapp · 1998 2 sentences 2003Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F 2003Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F	1	2003–2003
Malan v. General Dynamics Land Systems, Inc green michctapp · 1995 2 sentences 2003Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F 2003Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F	1	2003–2003
Rasheed v. Chrysler Corp. green mich · 1994 2 sentences 2003Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F 2003Malan v Gen Dynamics Land Sys, Inc, 212 Mich App 585, 587 ; 538 NW2d 76 (1995) (holding that a hostile-work-environment claim is actionable on the basis of any one of the enumerated classifications in MCL 37.2202), citing Rasheed v Chrysler Corp, 445 Mich 109 ; 517 NW2d 19 (1994) (religion-based harassment from coworkers and supervisors); Sumner, supra at 538 (race-based harassment from supervisors as a continuing violation); Meek v Michigan Bell Co, 193 Mich App 340, 342-343 ; 483 NW2d 407 (1992) (sex-based and religion-based harassment from supervisors); see also Jackson v Quanex Corp, 191 F	1	2003–2003
Mullins v. Rockwell International Corp. green cal · 1997 2 sentences 1998Further, the employer, who has created or permitted the persistence of known intolerable conditions, should not be able to complain of delay when the employee retains employment in the hope that conditions will improve or that informal conciliation may succeed. [Mullins v Rockwell Int’l Corp, 15 Cal 4th 731, 740; 63 Cal Rptr 2d 636; 936 P2d 1246 (1997) (citations omitted).] Hence we find no reason to address the other issues raised by the plaintiff, such as the continuing violation doctrine. 1998Further, the employer, who has created or permitted the persistence of known intolerable conditions, should not be able to complain of delay when the employee retains employment in the hope that conditions will improve or that informal conciliation may succeed. [ Mullins v. Rockwell Int'l Corp., 15 Cal.4th 731, 740 , 63 Cal.Rptr.2d 636 , 936 P.2d 1246 (1997) (citations omitted).] [23] Hence we find no reason to address the other issues raised by the plaintiff, such as the continuing violation doctrine. [24] We pause to again address the dissent's claim that our action impairs the function of t	1	1998–1998
Northville Public Schools v. Civil Rights Commission green michctapp · 1982 2 sentences 1986An appeal before the circuit court shall be reviewed de novo. [3] MCL 37.2101 et seq.; MSA 3.548(101) et seq. [4] See Northville Public Schools v Civil Rights Comm, 118 Mich App 573 ; 325 NW2d 497 (1982); Civil Rights Comm v Chrysler Corp, 80 Mich App 368 ; 263 NW2d 376 (1977). [5] 42 USC 2000e et seq. [6] MCL 423.301 et seq.; MSA 17.458(1) et seq., repealed by 1976 PA 453 , MCL 37.2101 et seq.; MSA 3.548(101) et seq. [7] MCL 37.1101 et seq.; MSA 3.550(101) et seq. [8] It should be noted that although the principle of equitable tolling of a statute of limitations is conceptually related to tha 1986An appeal before the circuit court shall be reviewed de novo. [3] MCL 37.2101 et seq.; MSA 3.548(101) et seq. [4] See Northville Public Schools v Civil Rights Comm, 118 Mich App 573 ; 325 NW2d 497 (1982); Civil Rights Comm v Chrysler Corp, 80 Mich App 368 ; 263 NW2d 376 (1977). [5] 42 USC 2000e et seq. [6] MCL 423.301 et seq.; MSA 17.458(1) et seq., repealed by 1976 PA 453 , MCL 37.2101 et seq.; MSA 3.548(101) et seq. [7] MCL 37.1101 et seq.; MSA 3.550(101) et seq. [8] It should be noted that although the principle of equitable tolling of a statute of limitations is conceptually related to tha	1	1986–1986
International Brotherhood of Teamsters v. United States green scotus · 1977 2 sentences 1986Indeed, in the companion case to Evans, Teamsters v United States, 431 US 324 ; 97 S Ct 1843 ; 52 L Ed 2d 396 (1977), the United States Supreme Court fashioned a remedy which took into account that part of the relevant injury occurring prior to the limitation period. 1986Indeed, in the companion case to Evans, Teamsters v United States, 431 US 324 ; 97 S Ct 1843 ; 52 L Ed 2d 396 (1977), the United States Supreme Court fashioned a remedy which took into account that part of the relevant injury occurring prior to the limitation period.	1	1986–1986
Civil Rights Commission v. Chrysler Corp. green michctapp · 1977 2 sentences 1986An appeal before the circuit court shall be reviewed de novo. [3] MCL 37.2101 et seq.; MSA 3.548(101) et seq. [4] See Northville Public Schools v Civil Rights Comm, 118 Mich App 573 ; 325 NW2d 497 (1982); Civil Rights Comm v Chrysler Corp, 80 Mich App 368 ; 263 NW2d 376 (1977). [5] 42 USC 2000e et seq. [6] MCL 423.301 et seq.; MSA 17.458(1) et seq., repealed by 1976 PA 453 , MCL 37.2101 et seq.; MSA 3.548(101) et seq. [7] MCL 37.1101 et seq.; MSA 3.550(101) et seq. [8] It should be noted that although the principle of equitable tolling of a statute of limitations is conceptually related to tha 1986An appeal before the circuit court shall be reviewed de novo. [3] MCL 37.2101 et seq.; MSA 3.548(101) et seq. [4] See Northville Public Schools v Civil Rights Comm, 118 Mich App 573 ; 325 NW2d 497 (1982); Civil Rights Comm v Chrysler Corp, 80 Mich App 368 ; 263 NW2d 376 (1977). [5] 42 USC 2000e et seq. [6] MCL 423.301 et seq.; MSA 17.458(1) et seq., repealed by 1976 PA 453 , MCL 37.2101 et seq.; MSA 3.548(101) et seq. [7] MCL 37.1101 et seq.; MSA 3.550(101) et seq. [8] It should be noted that although the principle of equitable tolling of a statute of limitations is conceptually related to tha	1	1986–1986
Miner v. Detroit Post & Tribune Co. green mich · 1882 2 sentences 1984In Miner v Detroit Post & Tribune Co, 49 Mich 358, 364 ; 13 NW 773 (1882), the Supreme Court held that the defendant had a privilege to bring to public light a judicial officer’s order which jailed a person even though no charge had first been filed against him and no bail had been required to be set: "Few duties can be plainer than to challenge public attention to the official disregard of the principles which protect public and personal liberty.” Likewise, in Stice v Beacon Newspaper Corp, Inc, 185 Kan 61; 340 P2d 396 ; 76 ALR2d 687 (1959), the Supreme Court of Kansas 50 held that a current 1984In Miner v Detroit Post & Tribune Co, 49 Mich 358, 364 ; 13 NW 773 (1882), the Supreme Court held that the defendant had a privilege to bring to public light a judicial officer’s order which jailed a person even though no charge had first been filed against him and no bail had been required to be set: "Few duties can be plainer than to challenge public attention to the official disregard of the principles which protect public and personal liberty.” Likewise, in Stice v Beacon Newspaper Corp, Inc, 185 Kan 61; 340 P2d 396 ; 76 ALR2d 687 (1959), the Supreme Court of Kansas 50 held that a current	1	1984–1984
Stice v. Beacon Newspaper Corporation green kan · 1959 1 sentence 1984In Miner v Detroit Post & Tribune Co, 49 Mich 358, 364 ; 13 NW 773 (1882), the Supreme Court held that the defendant had a privilege to bring to public light a judicial officer’s order which jailed a person even though no charge had first been filed against him and no bail had been required to be set: "Few duties can be plainer than to challenge public attention to the official disregard of the principles which protect public and personal liberty.” Likewise, in Stice v Beacon Newspaper Corp, Inc, 185 Kan 61; 340 P2d 396 ; 76 ALR2d 687 (1959), the Supreme Court of Kansas *50 held that a current	1	1984–1984

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 37.2101 (6) MI § Mich. Comp. Laws § 600.5827 (5) MI § Mich. Comp. Laws § 15.361 (3) MI § Mich. Comp. Laws § 37.1101 (3) MI § Mich. Comp. Laws § 37.2103 (3) MI § Mich. Comp. Laws § 552.601 (3) MI § Mich. Comp. Laws § 600.5809 (3) MI § Mich. Comp. Laws § 600.5821 (3) MI § Mich. Comp. Laws § 722.711 (3) MI § Mich. Comp. Laws § 750.165 (3) MI § Mich. Comp. Laws § 767.24 (3) MI § Mich. Comp. Laws § 8.3a (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

CA 155 (1941–2026) NY 113 (1910–2026) TX 101 (1960–2025) IL 91 (1910–2026) NJ 86 (1971–2026) MA 60 (1971–2025) PA 49 (1932–2026) NC 32 (1969–2025) AL 30 (1984–2023) WA 30 (1984–2026) OH 25 (1995–2026) MD 24 (1972–2021) CT 24 (1987–2024) MO 22 (1980–2025) FL 21 (1974–2025) MN 21 (1983–2025) MI 19 (1972–2024) IA 18 (1990–2021) GA 18 (1940–2024) DC 17 (1980–2020) TN 17 (1995–2026) LA 16 (1979–2019) WV 14 (1981–2025) WI 13 (1924–2026) VA 12 (1999–2025) CO 12 (1989–2026) VT 11 (1996–2026) OK 11 (1916–2014) ME 9 (1996–2025) WY 8 (1939–2000) NM 8 (1995–2018) AZ 8 (2008–2021) KS 7 (1980–2025) NH 7 (2006–2016) OR 7 (1977–2023) DE 6 (2015–2024) IN 6 (1984–2023) RI 6 (2005–2026) MS 6 (1940–2018) ID 5 (1984–2008) AK 5 (1994–2022) MT 5 (1999–2022) NE 4 (1929–2007) VI 4 (2005–2024) SD 4 (1980–2000) KY 4 (1992–2023) SC 3 (2015–2018) UT 2 (1992–2019) ND 2 (2009–2020)

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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