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12 Michigan opinions name it 2 courts 1966–2025 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.
| Case | Followed | Cited |
|---|---|---|
Burchett v. Delton-Kellogg Schoolgreen2 sentences1995In Burchett v Del-ton-Kellogg School, 378 Mich 231 ; 144 NW2d 337 (1966), the Supreme Court established an exception to this general principle known as the dual-purpose rule. 1995In Burchett v Del-ton-Kellogg School, 378 Mich 231 ; 144 NW2d 337 (1966), the Supreme Court established an exception to this general principle known as the dual-purpose rule. | 1 | 5 |
Howard v. City of Detroitgreen2 sentences1980Howard v Detroit, supra. Exemplary are those alluded to in Hills v Blair, supra, and the exceptions recognized in Howard v Detroit, supra, (Larson sees Howard as an application of the "special errand rule”, which he discusses in 1 Larson, §16.10, pp 4-123 et seq.); Burchett v Delton-Kellogg School, supra, (the "dual-purpose” doctrine), and Levchuk v Krug Cement Products Co, 246 Mich 589 ; 225 NW2d 559 (1929) (travel in employer-supplied vehicle). 1980The injuries in Hills v Blair, supra , although incurred during off-premises lunchtime travel, were not sustained in a motor vehicle accident. [43] Lasiewicki v Tusco Products Co, supra . [44] E.g., Burchett v Delton-Kellogg School, supra (applying the dual-purpose doctrine). [45] Howard v Detroit, supra . [46] An award of compensation in the instant cases need not, it is true, extend coverage to all motor vehicle accidental injuries sustained during the lunch period, regardless of the nature of the activity in which the employee was engaging. | 1 | 2 |
Hills v. Blairgreen2 sentences1980Howard v Detroit, supra. Exemplary are those alluded to in Hills v Blair, supra, and the exceptions recognized in Howard v Detroit, supra, (Larson sees Howard as an application of the "special errand rule”, which he discusses in 1 Larson, §16.10, pp 4-123 et seq.); Burchett v Delton-Kellogg School, supra, (the "dual-purpose” doctrine), and Levchuk v Krug Cement Products Co, 246 Mich 589 ; 225 NW2d 559 (1929) (travel in employer-supplied vehicle). 1980The injuries in Hills v Blair, supra , although incurred during off-premises lunchtime travel, were not sustained in a motor vehicle accident. [43] Lasiewicki v Tusco Products Co, supra . [44] E.g., Burchett v Delton-Kellogg School, supra (applying the dual-purpose doctrine). [45] Howard v Detroit, supra . [46] An award of compensation in the instant cases need not, it is true, extend coverage to all motor vehicle accidental injuries sustained during the lunch period, regardless of the nature of the activity in which the employee was engaging. | 1 | 2 |
Clifton v. Kroger Grocery & Baking Co.green2 sentences1966The dual-purpose rule was in effect in Michigan as long ago as 1922, when it was applied in Clifton v. Kroger Grocery & Baking Co., 217 Mich 462 , to justify an award of compensation to a store employee who was instructed, as a part of his duties, to take home with him each night for safekeeping all the money taken in at the store after banking hours, and where, while so doing, he was struck by an automobile and injured. 1966The existence of the dual-purpose doctrine in Michigan was established by the following cases: Punches v. American Box Board Co., 216 Mich 342 ; Clifton v. Kroger Grocery & Baking Co., 217 Mich 462 ; Anderson v. Kroger Grocery & Baking Co., 326 Mich 429 . | 1 | 2 |
Jackson v. Nelsongreen1 sentence2014See Jackson, 252 Mich App at 647 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Chambo v. City of Detroit
green
2 sentences2014Thus, for example, “[i]f a special trip would have had to be made if the employee had not combined this service with his going or coming trip, then the dual purpose rule applies.” Chambo v Detroit Police Dep’t, 83 Mich App 623, 626 ; 269 NW2d 243 (1978). 2014Thus, for example, “[i]f a special trip would have had to be made if the employee had not combined this service with his going or coming trip, then the dual purpose rule applies.” Chambo v Detroit Police Dep’t, 83 Mich App 623, 626 ; 269 NW2d 243 (1978). | 2 | 1995–2014 |
Levchuk v. Krug Cement Products Co.
neutral
2 sentences1980Howard v Detroit, supra. Exemplary are those alluded to in Hills v Blair, supra, and the exceptions recognized in Howard v Detroit, supra, (Larson sees Howard as an application of the "special errand rule”, which he discusses in 1 Larson, §16.10, pp 4-123 et seq.); Burchett v Delton-Kellogg School, supra, (the "dual-purpose” doctrine), and Levchuk v Krug Cement Products Co, 246 Mich 589 ; 225 NW2d 559 (1929) (travel in employer-supplied vehicle). 1980See fns 15 and 18, supra. Nonetheless, the rationale behind the proposed and perhaps any theoretically justifiable decisions in favor of the instant claimants is, logically, equally applicable to most lunchtime motor vehicle accident injuries, the number of which cannot be dismissed as insignificant. [47] Exemplary are those alluded to in Hills v Blair, supra , and the exceptions recognized in Howard v Detroit, supra , (Larson sees Howard as an application of the "special errand rule", which he discusses in 1 Larson, § 16.10, pp 4-123 et seq.); Burchett v Delton-Kellogg School, supra , (the "d | 2 | 1980–1980 |
Anderson v. Kroger Grocery & Baking Co.
green
2 sentences1966The existence of the dual-purpose doctrine in Michigan was established by the following cases: Punches v. American Box Board Co., 216 Mich 342 ; Clifton v. Kroger Grocery & Baking Co., 217 Mich 462 ; Anderson v. Kroger Grocery & Baking Co., 326 Mich 429 . 1966The existence of the dual-purpose doctrine in Michigan was established by the following cases: Punches v. American Box Board Co., 216 Mich 342 ; Clifton v. Kroger Grocery & Baking Co., 217 Mich 462 ; Anderson v. Kroger Grocery & Baking Co., 326 Mich 429 . | 2 | 1966–1974 |
Ten Brink v. Mokma
green
2 sentences2025“If the work of the employer creates the necessity for travel, [the employee] is in the course of his employment, though he is serving at the same time some purpose of his own.” Ten Brink v Mokma, 13 Mich App 85, 87 ; 163 NW2d 687 (1968) (cleaned up). 2025“If the work of the employer creates the necessity for travel, [the employee] is in the course of his employment, though he is serving at the same time some purpose of his own.” Ten Brink v Mokma, 13 Mich App 85, 87 ; 163 NW2d 687 (1968) (cleaned up). | 1 | 2025–2025 |
Kester v. Mattis, Inc
green
2 sentences2025Michigan courts recognize the dual-purpose rule, which states “that an employer is liable for the torts of his servant committed while going to or coming from work, if the employee’s trip involved a service of benefit to the employer.” Kester v Mattis, Inc, 44 Mich App 22, 24 ; 204 NW2d 741 (1972). 2025Michigan courts recognize the dual-purpose rule, which states “that an employer is liable for the torts of his servant committed while going to or coming from work, if the employee’s trip involved a service of benefit to the employer.” Kester v Mattis, Inc, 44 Mich App 22, 24 ; 204 NW2d 741 (1972). | 1 | 2025–2025 |
Bowman v. R L Coolsaet Construction Co.
green
1 sentence2014Bowman, 275 Mich App at 192 - 193. | 1 | 2014–2014 |
Thomas v. Certified Refrigeration, Inc
green
2 sentences2014The dual-purpose exception involves a benefit to the employer and applies in the context of employee use of a company vehicle where an employee acts under the general acceptance of the employer that company vehicles “would be used from time for time for personal purposes . . . .” Thomas v Certified Refrigeration, Inc, 392 Mich 623, 630 ; 221 NW2d 378 (1974). 2014The dual-purpose exception involves a benefit to the employer and applies in the context of employee use of a company vehicle where an employee acts under the general acceptance of the employer that company vehicles “would be used from time for time for personal purposes . . . .” Thomas v Certified Refrigeration, Inc, 392 Mich 623, 630 ; 221 NW2d 378 (1974). | 1 | 2014–2014 |
Stark v. LE Myers Company
green
2 sentences1995Under the dual-purpose exception, travel to and from work may be covered by the worker’s compensation act if at the time of the trip "the employer derived a special benefit from the employee’s activities at the time of the injury.” Chambo v Detroit, 83 Mich App 623, 627 ; 269 NW2d 243 (1978), quoting Stark v L E Myers Co, 58 Mich App 439, 443 ; 228 NW2d 411 (1975). 1995Under the dual-purpose exception, travel to and from work may be covered by the worker’s compensation act if at the time of the trip "the employer derived a special benefit from the employee’s activities at the time of the injury.” Chambo v Detroit, 83 Mich App 623, 627 ; 269 NW2d 243 (1978), quoting Stark v L E Myers Co, 58 Mich App 439, 443 ; 228 NW2d 411 (1975). | 1 | 1995–1995 |
Baas v. Society for Christian Instruction
green
2 sentences1966Possessing neither logic nor authority for overruling the entrenched dual-purpose doctrine, the controlling opinions in Baas v. Society for Chris tian Instruction, 371 Mich 622 , ignore it. 1966Murphy v. Flint Board of Education, 314 Mich 226 , and its progeny, Baas v. Society for Christian Instruction, 371 Mich 622 , are overruled to the extent that they deny compensation, without consideration of ■ the dual- purpose doctrine as to those injured, going to or coming from work. | 1 | 1966–1966 |
Murphy v. Flint Bd. of Education
green
2 sentences1966Murphy v. Flint Board of Education, 314 Mich 226 , and its progeny, Baas v. Society for Christian Instruction, 371 Mich 622 , are overruled to the extent that they deny compensation, without consideration of ■ the dual- purpose doctrine as to those injured, going to or coming from work. 1966Murphy v. Flint Board of Education, 314 Mich 226 , and its progeny, Baas v. Society for Christian Instruction, 371 Mich 622 , are overruled to the extent that they deny compensation, without consideration of ■ the dual- purpose doctrine as to those injured, going to or coming from work. | 1 | 1966–1966 |
Punches v. American Box Board Co.
green
2 sentences1966The existence of the dual-purpose doctrine in Michigan was established by the following cases: Punches v. American Box Board Co., 216 Mich 342 ; Clifton v. Kroger Grocery & Baking Co., 217 Mich 462 ; Anderson v. Kroger Grocery & Baking Co., 326 Mich 429 . 1966The existence of the dual-purpose doctrine in Michigan was established by the following cases: Punches v. American Box Board Co., 216 Mich 342 ; Clifton v. Kroger Grocery & Baking Co., 217 Mich 462 ; Anderson v. Kroger Grocery & Baking Co., 326 Mich 429 . | 1 | 1966–1966 |
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.