LaFontaine analysis (Michigan) · Go Syfert
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LaFontaine analysis in Michigan

11 Michigan opinions name it 2 courts 2016–2025 9 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 (2)

CaseFollowedCited
Lafontaine Saline, Inc v. Chrysler Group LLCgreen
mich · 2014 · cited in 9 Michigan opinions naming this issue, 2016–2025
2 sentences

2025Under a LaFontaine analysis, the first and often most important principle to consider is “whether there is specific language providing for retroactive application.” LaFontaine, 12 496 Mich at 38 .

2025Under a LaFontaine analysis, the first and often most important principle to consider is “whether there is specific language providing for retroactive application.” LaFontaine, 12 496 Mich at 38 .

39
Pontiac Police & Fire Retiree Prefunded Group Health & Insurance Trust Board of Trustees v. City of Pontiac No 1green
michctapp · 2015 · cited in 1 Michigan opinions naming this issue, 2016–2016
2 sentences

2016See City of Pontiac I, 309 Mich App at 607 (“[u]nder 2011 PA 4 , the EM could modify collective bargaining agreements, and, hence, could modify the city’s obligation to contribute to the trust”).

2016See City of Pontiac I, 309 Mich App at 607 (“[u]nder 2011 PA 4 , the EM could modify collective bargaining agreements, and, hence, could modify the city’s obligation to contribute to the trust”).

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 (3)

CaseCitedYears
In Re Certified Questions green
mich · 1982
2 sentences

2025STATUTORY CONSTRUCTION USING THE FOUR RULES In 1982, the U.S. Circuit Court of Appeals for the Sixth Circuit certified three questions to the Michigan Supreme Court, the first two of which involved statutory construction of the Michigan products liability statute, MCL 600.2945, et seq., including the issue of whether a plaintiff could be determined to be comparatively negligent in a claim alleging injury by breach of an implied warranty and the issue of whether the statute was to be given prospective or retroactive effect.5 In re Certified Questions from the United States Court of Appeals for

2025STATUTORY CONSTRUCTION USING THE FOUR RULES In 1982, the U.S. Circuit Court of Appeals for the Sixth Circuit certified three questions to the Michigan Supreme Court, the first two of which involved statutory construction of the Michigan products liability statute, MCL 600.2945, et seq., including the issue of whether a plaintiff could be determined to be comparatively negligent in a claim alleging injury by breach of an implied warranty and the issue of whether the statute was to be given prospective or retroactive effect.5 In re Certified Questions from the United States Court of Appeals for

12025–2025
Landgraf v. USI Film Products green
scotus · 1994
2 sentences

2016Having determined that the LaFontaine analysis is applicable to EO 225, we now analyze whether the extinguishment of defendant’s accrued but unpaid 2011-2012 fiscal year contribution to the trust is permissible under LaFontaine.2 The first principle to consider is “whether there is specific language providing for retroactive application.” LaFontaine, 496 1 This conclusion is supported by the fact that the United States Supreme Court has stated “that congressional enactments and administrative rules will not be construed to have retroactive effect unless their language requires this result.” La

2016Having determined that the LaFontaine analysis is applicable to EO 225, we now analyze whether the extinguishment of defendant’s accrued but unpaid 2011-2012 fiscal year contribution to the trust is permissible under LaFontaine.2 The first principle to consider is “whether there is specific language providing for retroactive application.” LaFontaine, 496 1 This conclusion is supported by the fact that the United States Supreme Court has stated “that congressional enactments and administrative rules will not be construed to have retroactive effect unless their language requires this result.” La

12016–2016
K & K Const. Inc. v. Deq green
michctapp · 2005
2 sentences

2016Having concluded that LaFontaine does apply, it is unnecessary to address what method for assessing the permissibility of retroactive effect would otherwise apply to this situation. *588 Finally, we note that plaintiffs supplemental brief on remand raises additional issues that are beyond the scope of our Supreme Court’s remand order. “[W]hen an appellate court gives clear instructions in its remand order, it is improper for a lower court to exceed the scope of the order.” K & K Constr, Inc v Dep’t of Environmental Quality, 267 Mich App 523, 544 ; 705 NW2d 365 (2005).

2016Having concluded that LaFontaine does apply, it is unnecessary to address what method for assessing the permissibility of retroactive effect would otherwise apply to this situation. *588 Finally, we note that plaintiffs supplemental brief on remand raises additional issues that are beyond the scope of our Supreme Court’s remand order. “[W]hen an appellate court gives clear instructions in its remand order, it is improper for a lower court to exceed the scope of the order.” K & K Constr, Inc v Dep’t of Environmental Quality, 267 Mich App 523, 544 ; 705 NW2d 365 (2005).

12016–2016

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 691.1402a (6) MI § Mich. Comp. Laws § 500.3101 (4) MI § Mich. Comp. Laws § 500.3110 (4) MI § Mich. Comp. Laws § 500.3142 (4) MI § Mich. Comp. Laws § 500.3157 (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

MI 11 (2016–2025) NY 11 (2011–2025) GA 8 (1998–2018)

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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