82 Michigan opinions name it 2 courts 1922–2026 20 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 |
|---|---|---|
Tarlea v. Crabtreegreen2 sentences2026The gross-negligence standard “suggests . . . almost a willful disregard of precautions or measures to attend to safety and a singular disregard for substantial risks,” Tarlea v Crabtree, 263 Mich App 80, 90 ; 687 NW2d 333 (2004), “as though . . . the actor simply did not care about the safety or welfare of those in his charge,” id. 2026The gross-negligence standard “suggests . . . almost a willful disregard of precautions or measures to attend to safety and a singular disregard for substantial risks,” Tarlea v Crabtree, 263 Mich App 80, 90 ; 687 NW2d 333 (2004), “as though . . . the actor simply did not care about the safety or welfare of those in his charge,” id. | 3 | 15 |
Odom v. Wayne Countygreen2 sentences2018To establish governmental immunity for a low-level employee against intentional torts, the defendant must show: “(1) the employee’s challenged acts were undertaken during the course of employment and that the employee was acting, or reasonably believed he was acting, within the scope of his authority, (2) the acts were undertaken in good faith, and (3) the acts were discretionary, rather than ministerial, in nature.” Odom v Wayne County, 482 Mich 459, 461, 468 ; 760 NW2d 217 (2008). 2017Thus, plaintiff did not state a claim on which relief could be granted.”) (citations omitted); see also Livermore [ex rel Rohm v Lubelan, 476 F 3d 397, 408 (CA 6, 2007)] (rejecting a gross-negligence claim against an officer-defendant because it was “undoubtedly premised on the intentional tort of battery” where it was based on a shooting that resulted in death). 3 In his brief on appeal, Bailey does not specifically identify the acts (or inactions) that he believes were grossly negligent. -5- (1) the acts were taken during the course of employment and the employees were acting, or reasonably | 3 | 3 |
Maiden v. Rozwoodgreen2 sentences2021In support of his argument that Michigan recognizes statutory gross negligence claims against government employees, plaintiff relies on Maiden v Rozwood, 461 Mich 109, 122 ; 597 NW2d 817 (1999), in which the Michigan Supreme Court stated that it would “consider the proof sufficient to survive a summary disposition of a gross negligence claim against a government employee.” (Emphasis added.) Although the Court referred to “a gross negligence claim against a government employee,” the Court expressly stated in a subsequent case that MCL 691.1407 “does not create a cause of action” and, instead, a 2021In support of his argument that Michigan recognizes statutory gross negligence claims against government employees, plaintiff relies on Maiden v Rozwood, 461 Mich 109, 122 ; 597 NW2d 817 (1999), in which the Michigan Supreme Court stated that it would “consider the proof sufficient to survive a summary disposition of a gross negligence claim against a government employee.” (Emphasis added.) Although the Court referred to “a gross negligence claim against a government employee,” the Court expressly stated in a subsequent case that MCL 691.1407 “does not create a cause of action” and, instead, a | 2 | 7 |
Gracey v. Wayne County Clerkgreen2 sentences1996The trial court also concluded that because defendants’ conduct was not the proximate cause of plaintiff’s injury, the gross negligence exception to governmental immunity, which at best would establish liability against only the individual officers, not the city, Gracey v Wayne Co Clerk, 213 Mich App 412 ; 540 NW2d 710 (1995), did not apply, and, as such, governmental immunity precluded plaintiff’s action. 1996The trial court also concluded that because defendants’ conduct was not the proximate cause of plaintiff’s injury, the gross negligence exception to governmental immunity, which at best would establish liability against only the individual officers, not the city, Gracey v Wayne Co Clerk, 213 Mich App 412 ; 540 NW2d 710 (1995), did not apply, and, as such, governmental immunity precluded plaintiff’s action. | 2 | 5 |
Wade v. Department of Correctionsgreen2 sentences1994Nearly identical language appeared in House Legislative Analysis Section, HB 5163, First and Second Analyses. [18] Both of the Senate Analysis Section analyses refer to language in the original and the amended Senate bills. [19] While Senator Pollack, using her constitutional right to protest, Const 1963, art 4, § 18, mentioned the gross negligence standard, she did not mention or attach any significance to the proximate cause requirement. [1] This Court has repeatedly recognized that legislative action, past and present, on the issue of governmental immunity "evidences a clear legislative jud 1994Nearly identical language appeared in House Legislative Analysis Section, HB 5163, First and Second Analyses. [18] Both of the Senate Analysis Section analyses refer to language in the original and the amended Senate bills. [19] While Senator Pollack, using her constitutional right to protest, Const 1963, art 4, § 18, mentioned the gross negligence standard, she did not mention or attach any significance to the proximate cause requirement. [1] This Court has repeatedly recognized that legislative action, past and present, on the issue of governmental immunity "evidences a clear legislative jud | 2 | 2 |
Abraham v. Jacksongreen2 sentences1993See also Abraham [v Jackson, 189 Mich App 367, 372 ; 473 NW2d 699 (1991)]. [Pavlov, supra, p 720 .] The Pavlov majority concluded that the trial court correctly dismissed the plaintiff’s gross negligence claim and declined the plaintiff’s request that it ignore the definition of gross negligence set out in Malcolm, Mallory, and Abraham and instead apply the standard found in MCL 691.1407(2) (c); MSA 3.996(107)(2)(c), which provides that "gross negligence” means "conduct so reckless as to demonstrate a substantial lack of concern for whether an injury results.” Pavlov, supra, pp 720-721 . 1993See also Abraham [v Jackson, 189 Mich App 367, 372 ; 473 NW2d 699 (1991)]. [Pavlov, supra, p 720 .] The Pavlov majority concluded that the trial court correctly dismissed the plaintiff’s gross negligence claim and declined the plaintiff’s request that it ignore the definition of gross negligence set out in Malcolm, Mallory, and Abraham and instead apply the standard found in MCL 691.1407(2) (c); MSA 3.996(107)(2)(c), which provides that "gross negligence” means "conduct so reckless as to demonstrate a substantial lack of concern for whether an injury results.” Pavlov, supra, pp 720-721 . | 2 | 2 |
American Transmissions, Inc v. Attorney Generalgreen2 sentences2022Gracey v Wayne Co Clerk, 213 Mich App 412, 420 ; 540 NW2d 710 (1995), abrogated on other grounds in American Transmissions, Inc v Attorney General, 454 Mich 135 ; 560 NW2d 50 (1997); see also Tarlea v Crabtree, 263 Mich App 80, 89 ; 687 NW2d 333 (2004). -4- Gross negligence is defined as “conduct so reckless as to demonstrate a substantial lack of concern for whether an injury results.” MCL 691.1407(8)(a). 2022Gracey v Wayne Co Clerk, 213 Mich App 412, 420 ; 540 NW2d 710 (1995), abrogated on other grounds in American Transmissions, Inc v Attorney General, 454 Mich 135 ; 560 NW2d 50 (1997); see also Tarlea v Crabtree, 263 Mich App 80, 89 ; 687 NW2d 333 (2004). -4- Gross negligence is defined as “conduct so reckless as to demonstrate a substantial lack of concern for whether an injury results.” MCL 691.1407(8)(a). | 1 | 4 |
Costa v. Community Emergency Medical Services, Incgreen2 sentences2010Maiden, 461 Mich 122 -123 (“[E]vidence of ordinary negligence does not create a material question of fact concerning gross negligence.”); see also Costa v Community Med Servs, Inc, 475 Mich 403, 411 ; 716 NW2d 236 (2006) (noting that the gross-negligence exception applies to situations “in which the contested conduct was substantially more than negligent”). 2010Maiden, 461 Mich 122 -123 (“[E]vidence of ordinary negligence does not create a material question of fact concerning gross negligence.”); see also Costa v Community Med Servs, Inc, 475 Mich 403, 411 ; 716 NW2d 236 (2006) (noting that the gross-negligence exception applies to situations “in which the contested conduct was substantially more than negligent”). | 1 | 2 |
Downs v. SAPERSTEIN ASSOCIATES CORP.green2 sentences2025See Dougherty v City of Detroit, 340 Mich App 339 , 346-347; 986 NW2d 467 (2021) (“Under the GTLA, a governmental employee is entitled to governmental immunity and, thus, summary disposition if the plaintiff fails to establish that the employee owed a duty in tort.”); Downs v Saperstein Assoc Corp, 265 Mich App 696, 699 ; 697 NW2d 190 (2005) (“Summary disposition of a gross negligence claim pursued under MCL 691.1407(2) is warranted if the plaintiff fails to establish a duty in tort.”). 2025See Dougherty v City of Detroit, 340 Mich App 339 , 346-347; 986 NW2d 467 (2021) (“Under the GTLA, a governmental employee is entitled to governmental immunity and, thus, summary disposition if the plaintiff fails to establish that the employee owed a duty in tort.”); Downs v Saperstein Assoc Corp, 265 Mich App 696, 699 ; 697 NW2d 190 (2005) (“Summary disposition of a gross negligence claim pursued under MCL 691.1407(2) is warranted if the plaintiff fails to establish a duty in tort.”). | 1 | 1 |
People of Michigan v. Christopher Duran Headgreen1 sentence2022See Head, 323 Mich App at 532 (stating that gross negligence involves a higher degree of culpability than recklessness); Schaefer, 473 Mich at 422 n 4 (stating that “the prosecution need not prove negligence or gross negligence by the defendant” under MCL 257.625(4)). | 1 | 1 |
Apostolos Paul Margaris v. Genesee Countygreen1 sentence2019See Margaris, 324 Mich App at 125 . -4- C. | 1 | 1 |
| Veldman v. City of Grand Rapidsgreen | 1 | 1 |
| Sherry v. East Suburban Football Leaguegreen | 1 | 1 |
| Heydon v. Mediaone of Southeast Michigan, Incgreen | 1 | 1 |
| Klanseck v. Anderson Sales & Service, Incgreen | 1 | 1 |
| Diem v. Sallie Mae Home Loans, Incgreen | 1 | 1 |
| Stein v. Michigan Employment Security Commissiongreen | 1 | 1 |
| People v. Heflingreen | 1 | 1 |
| People v. Barnesgreen | 1 | 1 |
| Gregg v. State Highway Departmentgreen | 1 | 1 |
| Chapadeau v. Utica Observer-Dispatch, Inc.green | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Robinson v. City of Detroit
green
2 sentences2008That provision states that a governmental employee is immune from tort liability if his “conduct does not amount to gross negligence that is the proximate cause of the injury or damage.” Unlike the motor-vehicle exception for governmental agencies, the gross-negligence exception for employees does not limit the waiver of immunity to cases of bodily injury or property damage. 13 Our decision to overrule Endykiewicz is warranted under the doctrine of stare decisis, as set forth in Robinson, supra at 463-464 . 2008That provision states that a governmental employee is immune from tort liability if his “conduct does not amount to gross negligence that is the proximate cause of the injury or damage.” Unlike the motor-vehicle exception for governmental agencies, the gross-negligence exception for employees does not limit the waiver of immunity to cases of bodily injury or property damage. 13 Our decision to overrule Endykiewicz is warranted under the doctrine of stare decisis, as set forth in Robinson, supra at 463-464 . | 6 | 2008–2026 |
Gibbard v. Cursan
red
2 sentences2017The difference is that between him who casts a missile intending that it shall strike another and him who casts it where he has reason to believe it will strike another, being indifferent whether it does so or not.” [Gibbard v Cursan, 225 Mich 311, 321 ; 196 NW 398 (1923), quoting Atchison, Topeka & Sante Fe R Co v Baker, 79 Kan 183; 98 P 804 (1908).] The Legislature’s approach to the gross negligence exception to governmental immunity sheds further light on the meaning of “recklessness” under Michigan law by equating the two concepts. 2017The difference is that between him who casts a missile intending that it shall strike another and him who casts it where he has reason to believe it will strike another, being indifferent whether it does so or not.” [Gibbard v Cursan, 225 Mich 311, 321 ; 196 NW 398 (1923), quoting Atchison, Topeka & Sante Fe R Co v Baker, 79 Kan 183; 98 P 804 (1908).] The Legislature’s approach to the gross negligence exception to governmental immunity sheds further light on the meaning of “recklessness” under Michigan law by equating the two concepts. | 6 | 1927–2017 |
Beaudrie v. Henderson
green
2 sentences2024“Summary disposition of a plaintiff’s gross negligence claim is proper under MCR 2.116(C)(8) if the plaintiff fails to establish a duty in tort.” Beaudrie v Henderson, 465 Mich 124, 130 ; 631 NW2d 308 (2001). 2024“Summary disposition of a plaintiff’s gross negligence claim is proper under MCR 2.116(C)(8) if the plaintiff fails to establish a duty in tort.” Beaudrie v Henderson, 465 Mich 124, 130 ; 631 NW2d 308 (2001). | 5 | 2005–2024 |
Bruce T Wood v. City of Detroit
green
2 sentences2023The allegations in Wright’s affidavit arguably justify a gross negligence claim; at a minimum, the evidence radically diverges regarding the nature of Hartley’s acts, and “questions regarding whether a governmental employee’s conduct constituted gross negligence are generally questions of fact for the jury[.]” Wood, 323 Mich App at 424 . 2022Under MCL 691.1407(8)(a), gross negligence is defined as “conduct so reckless as to demonstrate a substantial lack of concern for whether an injury results.” Although questions regarding whether conduct constituted gross negligence for purposes of governmental immunity are generally questions of fact for the jury, “if reasonable minds could not differ, summary disposition may be granted.” Wood v Detroit, 323 Mich App 416, 424 ; 917 NW2d 709 (2018). | 5 | 2021–2023 |
Ross v. Consumers Power Co.
red
2 sentences1994Nearly identical language appeared in House Legislative Analysis Section, HB 5163, First and Second Analyses. [18] Both of the Senate Analysis Section analyses refer to language in the original and the amended Senate bills. [19] While Senator Pollack, using her constitutional right to protest, Const 1963, art 4, § 18, mentioned the gross negligence standard, she did not mention or attach any significance to the proximate cause requirement. [1] This Court has repeatedly recognized that legislative action, past and present, on the issue of governmental immunity "evidences a clear legislative jud 1994Nearly identical language appeared in House Legislative Analysis Section, HB 5163, First and Second Analyses. [18] Both of the Senate Analysis Section analyses refer to language in the original and the amended Senate bills. [19] While Senator Pollack, using her constitutional right to protest, Const 1963, art 4, § 18, mentioned the gross negligence standard, she did not mention or attach any significance to the proximate cause requirement. [1] This Court has repeatedly recognized that legislative action, past and present, on the issue of governmental immunity "evidences a clear legislative jud | 3 | 1994–2019 |
Burnett v. City of Adrian
green
2 sentences1986I concur in the result but I am only willing to apply the gross negligence analysis of this opinion to cases arising under the recreational use act for the reasons stated in Burnett v City of Adrian, 414 Mich 448, 455 ; 326 NW2d 810 (1982). 1986I concur in the result but I am only willing to apply the gross negligence analysis of this opinion to cases arising under the recreational use act for the reasons stated in Burnett v City of Adrian, 414 Mich 448, 455 ; 326 NW2d 810 (1982). | 3 | 1983–1989 |
Oliver v. Smith
green
2 sentences2018The trial court denied defendant’s motion following oral arguments, relying on this Court’s holding in Oliver v Smith, 269 Mich App 560 ; 715 NW2d 314 (2006), that tight handcuffing can give rise to a gross negligence claim. 2018The trial court denied defendant’s motion following oral arguments, relying on this Court’s holding in Oliver v Smith, 269 Mich App 560 ; 715 NW2d 314 (2006), that tight handcuffing can give rise to a gross negligence claim. | 2 | 2018–2018 |
Love v. City of Detroit
green
2 sentences2018Michigan jurisprudence is clear that civil immunity is provided to governmental employees for injuries they cause while they are acting in the scope of their employment “if they are acting or reasonably believe they are acting within the scope of their authority, if they are engaged in the exercise or discharge of a governmental function, and if their conduct does not amount to gross negligence that is the proximate cause of the injury or damage.” Love v Detroit, 270 Mich App 563, 565 ; 716 NW2d 604 (2006), citing Robinson v Detroit, 462 Mich 439, 458 ; 613 NW2d 307 (2000), citing MCL 691.1407 2018Michigan jurisprudence is clear that civil immunity is provided to governmental employees for injuries they cause while they are acting in the scope of their employment “if they are acting or reasonably believe they are acting within the scope of their authority, if they are engaged in the exercise or discharge of a governmental function, and if their conduct does not amount to gross negligence that is the proximate cause of the injury or damage.” Love v Detroit, 270 Mich App 563, 565 ; 716 NW2d 604 (2006), citing Robinson v Detroit, 462 Mich 439, 458 ; 613 NW2d 307 (2000), citing MCL 691.1407 | 2 | 2018–2018 |
Malcolm v. City of East Detroit
green
2 sentences1993The panel in Malcolm v East Detroit, 180 Mich App 633, 643 ; 447 NW2d 860 (1989), applied the same rule: "[F]or a gross negligence claim to be actionable it must allege that the defendant’s negligent conduct occurred subsequent to some negligent conduct on the part of the plaintiff.” The Supreme Court reversed the Malcolm decision on other grounds, but did not address the definition of "gross negligence” because the plaintiff failed to raise it on cross-appeal. 437 Mich 132, 147-148 ; 468 NW2d 479 (1991). 1993The panel in Malcolm v East Detroit, 180 Mich App 633, 643 ; 447 NW2d 860 (1989), applied the same rule: "[F]or a gross negligence claim to be actionable it must allege that the defendant’s negligent conduct occurred subsequent to some negligent conduct on the part of the plaintiff.” The Supreme Court reversed the Malcolm decision on other grounds, but did not address the definition of "gross negligence” because the plaintiff failed to raise it on cross-appeal. 437 Mich 132, 147-148 ; 468 NW2d 479 (1991). | 2 | 1992–1993 |
Malcolm v. City of East Detroit
green
2 sentences1993The panel in Malcolm v East Detroit, 180 Mich App 633, 643 ; 447 NW2d 860 (1989), applied the same rule: "[F]or a gross negligence claim to be actionable it must allege that the defendant’s negligent conduct occurred subsequent to some negligent conduct on the part of the plaintiff.” The Supreme Court reversed the Malcolm decision on other grounds, but did not address the definition of "gross negligence” because the plaintiff failed to raise it on cross-appeal. 437 Mich 132, 147-148 ; 468 NW2d 479 (1991). 1993The panel in Malcolm v East Detroit, 180 Mich App 633, 643 ; 447 NW2d 860 (1989), applied the same rule: "[F]or a gross negligence claim to be actionable it must allege that the defendant’s negligent conduct occurred subsequent to some negligent conduct on the part of the plaintiff.” The Supreme Court reversed the Malcolm decision on other grounds, but did not address the definition of "gross negligence” because the plaintiff failed to raise it on cross-appeal. 437 Mich 132, 147-148 ; 468 NW2d 479 (1991). | 2 | 1992–1993 |
Latits v. Phillips
green
2 sentences2024“Moreover, this Court has rejected attempts to transform claims involving elements of intentional torts into claims of gross negligence.” Latits v Phillips, 298 Mich App 109, 120 ; 826 NW2d 190 (2012). 2024“Moreover, this Court has rejected attempts to transform claims involving elements of intentional torts into claims of gross negligence.” Latits v Phillips, 298 Mich App 109, 120 ; 826 NW2d 190 (2012). | 1 | 2024–2024 |
Heather Lynn Hannay v. Department of Transportation
green
1 sentence2024MCL 691.1407(1); Hannay v Dep’t of Transp, 497 Mich 45, 58-60 ; 860 NW2d 67 (2014). | 1 | 2024–2024 |
Hamed v. Wayne County
green
2 sentences2023MCL 691.1407(2) provides governmental employees with immunity from tort liability for injuries caused by the employee while in the course of their employment so long as the following conditions are met: (a) The officer, employee, member, or volunteer is acting or reasonably believes he or she is acting within the scope of his or her authority. law doctrine, as articulated in Hamed v Wayne Co, 490 Mich 1, 12-13 ; 803 NW2d 237 (2011) (holding that an employer may be liable for its employee’s conduct if the employer knew or should have known of the employee’s propensities and criminal record, and 2023MCL 691.1407(2) provides governmental employees with immunity from tort liability for injuries caused by the employee while in the course of their employment so long as the following conditions are met: (a) The officer, employee, member, or volunteer is acting or reasonably believes he or she is acting within the scope of his or her authority. law doctrine, as articulated in Hamed v Wayne Co, 490 Mich 1, 12-13 ; 803 NW2d 237 (2011) (holding that an employer may be liable for its employee’s conduct if the employer knew or should have known of the employee’s propensities and criminal record, and | 1 | 2023–2023 |
Beals v. Michigan
green
2 sentences2023GROSS NEGLIGENCE Next, Beal argues that the trial court erred by granting summary disposition in favor of Officer Stanton on the gross negligence claim. -6- The GTLA “affords broad immunity from tort liability to governmental agencies and their employees whenever they are engaged in the exercise or discharge of a governmental function.” Beals v Michigan, 497 Mich 363, 370 ; 871 NW2d 5 (2015). 2023GROSS NEGLIGENCE Next, Beal argues that the trial court erred by granting summary disposition in favor of Officer Stanton on the gross negligence claim. -6- The GTLA “affords broad immunity from tort liability to governmental agencies and their employees whenever they are engaged in the exercise or discharge of a governmental function.” Beals v Michigan, 497 Mich 363, 370 ; 871 NW2d 5 (2015). | 1 | 2023–2023 |
Gleason v. Department of Transportation
green
2 sentences2022Nevertheless, “[a] trial court’s ruling may be upheld on appeal where the right result issued, albeit for the wrong reason.” Gleason v Dep’t of Transp, 256 Mich App, 1, 3 ; 662 NW2d 822 (2003). “[G]overnmental immunity is a characteristic of government,” and “[a]s such, plaintiff must plead her case in avoidance of immunity.” Mack v City of Detroit, 467 Mich 186, 198 ; 649 NW2d 47 (2002). 2022Nevertheless, “[a] trial court’s ruling may be upheld on appeal where the right result issued, albeit for the wrong reason.” Gleason v Dep’t of Transp, 256 Mich App, 1, 3 ; 662 NW2d 822 (2003). “[G]overnmental immunity is a characteristic of government,” and “[a]s such, plaintiff must plead her case in avoidance of immunity.” Mack v City of Detroit, 467 Mich 186, 198 ; 649 NW2d 47 (2002). | 1 | 2022–2022 |
Xu v. Gay
green
2 sentences2022We vacated the grant of summary disposition regarding Richards’s claims of gross negligence,2 and directed the trial court to apply the gross negligence standard articulated in Xu v Gay, 257 Mich App 263, 269 ; 668 NW2d 166 (2003). 2022We vacated the grant of summary disposition regarding Richards’s claims of gross negligence,2 and directed the trial court to apply the gross negligence standard articulated in Xu v Gay, 257 Mich App 263, 269 ; 668 NW2d 166 (2003). | 1 | 2022–2022 |
People v. Schaefer
green
1 sentence2022See Head, 323 Mich App at 532 (stating that gross negligence involves a higher degree of culpability than recklessness); Schaefer, 473 Mich at 422 n 4 (stating that “the prosecution need not prove negligence or gross negligence by the defendant” under MCL 257.625(4)). | 1 | 2022–2022 |
MacK v. City of Detroit
green
2 sentences2022Nevertheless, “[a] trial court’s ruling may be upheld on appeal where the right result issued, albeit for the wrong reason.” Gleason v Dep’t of Transp, 256 Mich App, 1, 3 ; 662 NW2d 822 (2003). “[G]overnmental immunity is a characteristic of government,” and “[a]s such, plaintiff must plead her case in avoidance of immunity.” Mack v City of Detroit, 467 Mich 186, 198 ; 649 NW2d 47 (2002). 2022Nevertheless, “[a] trial court’s ruling may be upheld on appeal where the right result issued, albeit for the wrong reason.” Gleason v Dep’t of Transp, 256 Mich App, 1, 3 ; 662 NW2d 822 (2003). “[G]overnmental immunity is a characteristic of government,” and “[a]s such, plaintiff must plead her case in avoidance of immunity.” Mack v City of Detroit, 467 Mich 186, 198 ; 649 NW2d 47 (2002). | 1 | 2022–2022 |
| VanVorous v. Burmeister green | 1 | 2019–2019 |
| Allen v. Owens-Corning Fiberglas Corp. green | 1 | 2019–2019 |
Bell v. Porter
green
1 sentence2019The federal district court noted that the gross negligence claim was predicated on the same conduct that gave rise to the allegations of excessive force and assault and battery, but concluded that gross negligence was a valid alternative because the plaintiff’s claim that the offending officer failed to treat her with respect and dignity, to avoid foreseeable injury to her, and to “avoid conduct or a failure to act that is so reckless that it demonstrates a substantial lack of concern for whether an injury will result,” did not “rely on an intentional, offensive touching.” Id. at 1015 , distin | 1 | 2019–2019 |
| Atchison, Topeka & Santa Fe Railway Co. v. Baker green | 1 | 2017–2017 |
| Amperse v. Winslow green | 1 | 2017–2017 |
| Moffatt v. Helmer green | 1 | 2016–2016 |
| Vandervelt v. Mather neutral | 1 | 2016–2016 |
| Smith v. Stolberg green | 1 | 2015–2015 |
| Sewell v. Southfield Public Schools green | 1 | 2015–2015 |
| Ritchie-Gamester v. City of Berkley green | 1 | 2011–2011 |
| Dean v. Childs red | 1 | 2005–2005 |
| Dean v. Childs red | 1 | 2005–2005 |
| Koenig v. City of South Haven green | 1 | 1999–1999 |
| Haberl v. Rose green | 1 | 1999–1999 |
| Jackson v. Saginaw County green | 1 | 1999–1999 |
| People v. Quinn green | 1 | 1998–1998 |
| White v. Beasley green | 1 | 1997–1997 |
| Dedes v. South Lyon Community Schools neutral | 1 | 1996–1996 |
| People v. Pavlic green | 1 | 1995–1995 |
| People v. Campbell green | 1 | 1995–1995 |
| People v. Orr green | 1 | 1995–1995 |
| Patterson v. Kleiman green | 1 | 1995–1995 |
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.