position or assert error in Michigan

2026“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” Mitcham v Detroit, 355 Mich 182, 203 ; 94 NW2d 388 (1959).

2026“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” Mitcham v Detroit, 355 Mich 182, 203 ; 94 NW2d 388 (1959).

2026An appellant may not simply “announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority to either sustain or reject his position.” People v Kevorkian, 248 Mich App 373, 389 ; 639 NW2d 291 (2001) (quotation marks and citation omitted).

2026An appellant may not simply “announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority to either sustain or reject his position.” People v Kevorkian, 248 Mich App 373, 389 ; 639 NW2d 291 (2001) (quotation marks and citation omitted).

2026“It is not sufficient for a party simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” Wilson v Taylor, 457 Mich 232, 243 ; 577 NW2d 100 (1998) (quotation marks and citation omitted).

2026“It is not sufficient for a party simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” Wilson v Taylor, 457 Mich 232, 243 ; 577 NW2d 100 (1998) (quotation marks and citation omitted).

2024See Mudge v Macomb Co, 458 Mich 87, 105 ; 580 NW2d 845 (1998) (“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.”) (quotation marks and citation omitted).

2024See Mudge v Macomb Co, 458 Mich 87, 105 ; 580 NW2d 845 (1998) (“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.”) (quotation marks and citation omitted).

2026Even if these text messages were taken at face value as authentic, unadulterated, and complete, Gilliam does not explain how the messages undermine CD’s testimony.5 See People v Bowling, 299 Mich App 552, 559-560 ; 830 NW2d 800 (2013) (stating that an appellant may not simply “announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments”).

2026Even if these text messages were taken at face value as authentic, unadulterated, and complete, Gilliam does not explain how the messages undermine CD’s testimony.5 See People v Bowling, 299 Mich App 552, 559-560 ; 830 NW2d 800 (2013) (stating that an appellant may not simply “announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments”).

2026“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims . . . .” Yee v Shiawassee Co Bd of Comm’rs, 251 Mich App 379, 406 ; 651 NW2d 756 (2002) (quotation marks and citation omitted).

2026“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims . . . .” Yee v Shiawassee Co Bd of Comm’rs, 251 Mich App 379, 406 ; 651 NW2d 756 (2002) (quotation marks and citation omitted).

2019“An appellant may not . . . give issues cursory treatment with little or no citation of supporting authority.” Houghton ex rel Johnson v Keller, 256 Mich App 336, 339 ; 662 NW2d 854 (2003); see also People v Kevorkian, 248 Mich App 373, 389 ; 639 NW2d 291 (2001) (“[i]t is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position”).

2019“An appellant may not . . . give issues cursory treatment with little or no citation of supporting authority.” Houghton ex rel Johnson v Keller, 256 Mich App 336, 339 ; 662 NW2d 854 (2003); see also People v Kevorkian, 248 Mich App 373, 389 ; 639 NW2d 291 (2001) (“[i]t is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position”).

2025See People v Bass, 317 Mich App 241, 276 ; 893 NW2d 140 (2016) (“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims . . . .” (citation omitted)).

2025See People v Bass, 317 Mich App 241, 276 ; 893 NW2d 140 (2016) (“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims . . . .” (citation omitted)).

2024See People v Kammeraad, 307 Mich App 98, 143 ; 858 NW2d 490 (2014) (“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” (quotation marks and citation omitted).] With respect to the portion of defendant’s argument pertaining to the prosecutor’s discretion, all challenges for cause on whatever grounds in MCR 2.511(D)(10) necessarily implicate di

2024See People v Kammeraad, 307 Mich App 98, 143 ; 858 NW2d 490 (2014) (“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” (quotation marks and citation omitted).] With respect to the portion of defendant’s argument pertaining to the prosecutor’s discretion, all challenges for cause on whatever grounds in MCR 2.511(D)(10) necessarily implicate di

2024“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” People v Waclawski, 286 Mich App 634, 679 ; 780 NW2d 321 (2009) (quotation marks and citation omitted).

2024“It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” People v Waclawski, 286 Mich App 634, 679 ; 780 NW2d 321 (2009) (quotation marks and citation omitted).

2026An appellant may not “simply announce a position or assert an error in [its] brief and then leave it up to this Court to discover and rationalize the basis for the claims, or unravel and elaborate the appellant’s arguments, and then search for authority to either sustain or reject the appellant’s position.” DeGeorge v Warheit, 276 Mich App 587 , 594- 595; 741 NW2d 384 (2007).

2026An appellant may not “simply announce a position or assert an error in [its] brief and then leave it up to this Court to discover and rationalize the basis for the claims, or unravel and elaborate the appellant’s arguments, and then search for authority to either sustain or reject the appellant’s position.” DeGeorge v Warheit, 276 Mich App 587 , 594- 595; 741 NW2d 384 (2007).

2025See People v Burkett, 337 Mich App 631 , 639 n 4; 976 NW2d 864 (2021) (“[A]n appellant may not simply announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.”) (quotation marks and citation omitted).

2025See People v Burkett, 337 Mich App 631 , 639 n 4; 976 NW2d 864 (2021) (“[A]n appellant may not simply announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.”) (quotation marks and citation omitted).

2022An appellant may not merely “announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” People v Martin, 271 Mich App 280, 315 ; 721 NW2d 815 (2006) (quotation marks and citation omitted).

2022An appellant may not merely “announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” People v Martin, 271 Mich App 280, 315 ; 721 NW2d 815 (2006) (quotation marks and citation omitted).

2024See 1031 Lapeer LLC v Rice, 290 Mich App 225, 233-234 ; 810 NW2d 293 (2010) (stating that an appellant may not “simply announce a position or assert an error and then leave it to this Court to discover and rationalize the basis for the appellant’s claims, unravel and elaborate upon the arguments, and search for the authority to support his or her position”).

2024See 1031 Lapeer LLC v Rice, 290 Mich App 225, 233-234 ; 810 NW2d 293 (2010) (stating that an appellant may not “simply announce a position or assert an error and then leave it to this Court to discover and rationalize the basis for the appellant’s claims, unravel and elaborate upon the arguments, and search for the authority to support his or her position”).

2026However, courts do not serve as research assistants for the parties before them, Walters v Nadell, 481 Mich 377, 388 ; 751 NW2d 431 (2008), and an appellant may not simply announce a position or assert an error and leave it up to this Court to discover and rationalize the basis of the claims, elaborate the parties’ arguments, or search for authority in support, Mitcham, 355 Mich at 203 .

2026However, courts do not serve as research assistants for the parties before them, Walters v Nadell, 481 Mich 377, 388 ; 751 NW2d 431 (2008), and an appellant may not simply announce a position or assert an error and leave it up to this Court to discover and rationalize the basis of the claims, elaborate the parties’ arguments, or search for authority in support, Mitcham, 355 Mich at 203 .

2024See People v Bowling, 299 Mich App 552, 559-560 ; 830 NW2d 800 (2013) (quotation marks and citation omitted) (“As we have repeatedly stated, an appellant may not simply announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.”); People v McGraw, 484 Mich 120 , 131 n 36; 771 NW2d 655 (2009) (“Failure to brief an issue on appeal constitutes abandonment.”).

2024See People v Bowling, 299 Mich App 552, 559-560 ; 830 NW2d 800 (2013) (quotation marks and citation omitted) (“As we have repeatedly stated, an appellant may not simply announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.”); People v McGraw, 484 Mich 120 , 131 n 36; 771 NW2d 655 (2009) (“Failure to brief an issue on appeal constitutes abandonment.”).

2018Furthermore, “[i]t is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” Goolsby v City of Detroit, 419 Mich 651 , 655 n 1; 358 NW2d 856 (1984) (quotation marks and citation omitted).

2018Furthermore, “[i]t is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” Goolsby v City of Detroit, 419 Mich 651 , 655 n 1; 358 NW2d 856 (1984) (quotation marks and citation omitted).

2026It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority to either sustain or reject his position. [Riemer v Johnson, 311 Mich App 632, 653 ; 876 NW2d 279 (2015) (quotation marks and citation omitted).] By failing to properly brief the merits of his assertion of error, defendant has abandoned the issue on appeal.

2026It is not enough for an appellant in his brief simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority to either sustain or reject his position. [Riemer v Johnson, 311 Mich App 632, 653 ; 876 NW2d 279 (2015) (quotation marks and citation omitted).] By failing to properly brief the merits of his assertion of error, defendant has abandoned the issue on appeal.

2022Respondent has not provided any evidence to suggest that petitioner had any control over when respondent took her medication, and “[i]t is not sufficient for a party simply to announce a position or assert an error and then leave it up to this Court to . . . search for authority either to sustain or reject [her] position.” Innovation Ventures v Liquid Mfg, 499 Mich 491, 518 ; 885 NW2d 861 (2016) (quotation marks and citation omitted).

2022Respondent has not provided any evidence to suggest that petitioner had any control over when respondent took her medication, and “[i]t is not sufficient for a party simply to announce a position or assert an error and then leave it up to this Court to . . . search for authority either to sustain or reject [her] position.” Innovation Ventures v Liquid Mfg, 499 Mich 491, 518 ; 885 NW2d 861 (2016) (quotation marks and citation omitted).

2026“It is not sufficient for a party simply to announce a position or assert an error and then leave it [up] to . . . this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” Oakland Co v Michigan, 325 Mich App 247, 266-267 ; 926 NW2d 11 (2018) (citation omitted).

2026“It is not sufficient for a party simply to announce a position or assert an error and then leave it [up] to . . . this Court to discover and rationalize the basis for his claims, or unravel and elaborate for him his arguments, and then search for authority either to sustain or reject his position.” Oakland Co v Michigan, 325 Mich App 247, 266-267 ; 926 NW2d 11 (2018) (citation omitted).

2026“It is not enough for an appellant . . . simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims . . . and then search for authority either to sustain or reject his position.” People v Beck, 510 Mich 1 , 26; 987 NW2d 1 (2022) (quotation marks and citation omitted; alteration in original). 4 Although there is no requirement to place a defendant’s waiver on the record, People v Harris, 190 Mich App 652, 661 ; 476 NW2d 767 (1991), it was done so here. -7- advice, and raised no concerns or questions about that waiver.

2026“It is not enough for an appellant . . . simply to announce a position or assert an error and then leave it up to this Court to discover and rationalize the basis for his claims . . . and then search for authority either to sustain or reject his position.” People v Beck, 510 Mich 1 , 26; 987 NW2d 1 (2022) (quotation marks and citation omitted; alteration in original). 4 Although there is no requirement to place a defendant’s waiver on the record, People v Harris, 190 Mich App 652, 661 ; 476 NW2d 767 (1991), it was done so here. -7- advice, and raised no concerns or questions about that waiver.

2025See, e.g., People v Smith, 336 Mich App 79 , 112; 969 NW2d 548 (2021) (hearsay argument deemed abandoned where the defendant offered no hearsay argument with respect to the evidence in his appellate brief); see also Franks v Franks, 330 Mich App 69 , 109 n 5; 944 NW2d 388 (2019) (holding that appellants abandoned issue that was raised in their statement of questions presented but not addressed in their brief on appeal), citing Mitcham v Detroit, 355 Mich 182 ; 94 NW2d 388 (1959); In re Contempt of Henry, 282 Mich App 656, 670 ; 765 NW2d 44 (2009) (“It is not sufficient for a party simply to an

2025See, e.g., People v Smith, 336 Mich App 79 , 112; 969 NW2d 548 (2021) (hearsay argument deemed abandoned where the defendant offered no hearsay argument with respect to the evidence in his appellate brief); see also Franks v Franks, 330 Mich App 69 , 109 n 5; 944 NW2d 388 (2019) (holding that appellants abandoned issue that was raised in their statement of questions presented but not addressed in their brief on appeal), citing Mitcham v Detroit, 355 Mich 182 ; 94 NW2d 388 (1959); In re Contempt of Henry, 282 Mich App 656, 670 ; 765 NW2d 44 (2009) (“It is not sufficient for a party simply to an

2019“Failure to brief a question on appeal is tantamount to abandoning it.” Id.; see also People v Matuszak, 263 Mich App 42, 59 ; 687 NW2d 342 (2004) (“Such cursory treatment constitutes abandonment of the issue.”).

2019“Failure to brief a question on appeal is tantamount to abandoning it.” Id.; see also People v Matuszak, 263 Mich App 42, 59 ; 687 NW2d 342 (2004) (“Such cursory treatment constitutes abandonment of the issue.”).