pari delicto doctrine (Michigan) · Go Syfert
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pari delicto doctrine in Michigan

9 Michigan opinions name it 1 courts 1996–2025 3 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 (5)

CaseFollowedCited
Orzel v. Scott Drug Co.green
mich · 1995 · cited in 8 Michigan opinions naming this issue, 1996–2025
2 sentences

2025Under the doctrine of in pari delicto, when the parties are equally in the wrong, “the law will not lend itself to afford relief to one as against the other, but will leave them as it finds them.” Orzel v Scott Drug Co, 449 Mich 550, 558 ; 537 NW2d 208 (1995) (quotation marks and citation).

2025Under the doctrine of in pari delicto, when the parties are equally in the wrong, “the law will not lend itself to afford relief to one as against the other, but will leave them as it finds them.” Orzel v Scott Drug Co, 449 Mich 550, 558 ; 537 NW2d 208 (1995) (quotation marks and citation).

28
Pantely v. Garris, Garris & Garris, PCgreen
michctapp · 1989 · cited in 3 Michigan opinions naming this issue, 2014–2017
2 sentences

2014In Pantely v Garris & Garris, PC, 180 Mich App 768 ; 447 NW2d 864 (1989), which predated Orzel, this Court applied the doctrine of in pari delicto to bar the plaintiff’s legal malpractice claim against the attorneys and law firm that represented her in her divorce proceedings.

2014In Pantely v Garris & Garris, PC, 180 Mich App 768 ; 447 NW2d 864 (1989), which predated Orzel, this Court applied the doctrine of in pari delicto to bar the plaintiff’s legal malpractice claim against the attorneys and law firm that represented her in her divorce proceedings.

23
Hanton v. Hantz Financial Services, Inc.green
michctapp · 2014 · cited in 2 Michigan opinions naming this issue, 2017–2017
2 sentences

2017See also Pantely v Garris, Garris & Garris, PC, 180 Mich App 768, 774 ; 447 NW2d 864 (1989) (“In pari delicto, as a common law doctrine, expresses the principle that wrongdoers ought each to bear the untoward consequences of their 4 See Demski v Petlick, 309 Mich App 404, 441 ; 873 NW2d 596 (2015) (“[T]his Court will affirm when the trial court reaches the right result for the wrong reason.”); Hanton v Hantz Fin Servs, Inc, 306 Mich App 654, 669 ; 858 NW2d 481 (2014) (“An appellee may argue alternative grounds for affirmance without filing a cross-appeal if the appellee does not seek a more fa

2017See also Pantely v Garris, Garris & Garris, PC, 180 Mich App 768, 774 ; 447 NW2d 864 (1989) (“In pari delicto, as a common law doctrine, expresses the principle that wrongdoers ought each to bear the untoward consequences of their 4 See Demski v Petlick, 309 Mich App 404, 441 ; 873 NW2d 596 (2015) (“[T]his Court will affirm when the trial court reaches the right result for the wrong reason.”); Hanton v Hantz Fin Servs, Inc, 306 Mich App 654, 669 ; 858 NW2d 481 (2014) (“An appellee may argue alternative grounds for affirmance without filing a cross-appeal if the appellee does not seek a more fa

22
Graham v. Fostergreen
mich · 2016 · cited in 2 Michigan opinions naming this issue, 2017–2017
2 sentences

2017See also Pantely v Garris, Garris & Garris, PC, 180 Mich App 768, 774 ; 447 NW2d 864 (1989) (“In pari delicto, as a common law doctrine, expresses the principle that wrongdoers ought each to bear the untoward consequences of their 4 See Demski v Petlick, 309 Mich App 404, 441 ; 873 NW2d 596 (2015) (“[T]his Court will affirm when the trial court reaches the right result for the wrong reason.”); Hanton v Hantz Fin Servs, Inc, 306 Mich App 654, 669 ; 858 NW2d 481 (2014) (“An appellee may argue alternative grounds for affirmance without filing a cross-appeal if the appellee does not seek a more fa

2017See also Pantely v Garris, Garris & Garris, PC, 180 Mich App 768, 774 ; 447 NW2d 864 (1989) (“In pari delicto, as a common law doctrine, expresses the principle that wrongdoers ought each to bear the untoward consequences of their 4 See Demski v Petlick, 309 Mich App 404, 441 ; 873 NW2d 596 (2015) (“[T]his Court will affirm when the trial court reaches the right result for the wrong reason.”); Hanton v Hantz Fin Servs, Inc, 306 Mich App 654, 669 ; 858 NW2d 481 (2014) (“An appellee may argue alternative grounds for affirmance without filing a cross-appeal if the appellee does not seek a more fa

22
T.M. v. M.Z.green
mich · 2018 · cited in 1 Michigan opinions naming this issue, 2021–2021
2 sentences

2021See TM v MZ, 501 Mich 312, 317 ; 916 NW2d 473 (2018). -11- When a plaintiff’s action is based on his own illegal conduct, and the defendant has participated equally in the illegal activity, a similar common-law maxim, known as the “doctrine of in pari delicto” generally applies to also bar the plaintiff’s claim: [A]s between parties in pari delicto, that is equally in the wrong, the law will not lend itself to afford relief to one as against the other, but will leave them as it finds them. (1A CJS, Actions, § 29, p 388.

2021See TM v MZ, 501 Mich 312, 317 ; 916 NW2d 473 (2018). -11- When a plaintiff’s action is based on his own illegal conduct, and the defendant has participated equally in the illegal activity, a similar common-law maxim, known as the “doctrine of in pari delicto” generally applies to also bar the plaintiff’s claim: [A]s between parties in pari delicto, that is equally in the wrong, the law will not lend itself to afford relief to one as against the other, but will leave them as it finds them. (1A CJS, Actions, § 29, p 388.

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 (2)

CaseCitedYears
Demski v. Petlick green
michctapp · 2015
2 sentences

2017See also Pantely v Garris, Garris & Garris, PC, 180 Mich App 768, 774 ; 447 NW2d 864 (1989) (“In pari delicto, as a common law doctrine, expresses the principle that wrongdoers ought each to bear the untoward consequences of their 4 See Demski v Petlick, 309 Mich App 404, 441 ; 873 NW2d 596 (2015) (“[T]his Court will affirm when the trial court reaches the right result for the wrong reason.”); Hanton v Hantz Fin Servs, Inc, 306 Mich App 654, 669 ; 858 NW2d 481 (2014) (“An appellee may argue alternative grounds for affirmance without filing a cross-appeal if the appellee does not seek a more fa

2017See also Pantely v Garris, Garris & Garris, PC, 180 Mich App 768, 774 ; 447 NW2d 864 (1989) (“In pari delicto, as a common law doctrine, expresses the principle that wrongdoers ought each to bear the untoward consequences of their 4 See Demski v Petlick, 309 Mich App 404, 441 ; 873 NW2d 596 (2015) (“[T]his Court will affirm when the trial court reaches the right result for the wrong reason.”); Hanton v Hantz Fin Servs, Inc, 306 Mich App 654, 669 ; 858 NW2d 481 (2014) (“An appellee may argue alternative grounds for affirmance without filing a cross-appeal if the appellee does not seek a more fa

22017–2017
Manning v. Bishop of Marquette green
mich · 1956
2 sentences

2015Similarly, under the doctrine of pari delicto, when an action is based on a plaintiff’s illegal conduct in which the defendant has also participated, courts will not “decide, as between two scoundrels, who cheated whom the more.” Manning v Noa, 345 Mich 130, 133 ; 76 NW2d 75 (1956).

2015Similarly, under the doctrine of pari delicto, when an action is based on a plaintiff’s illegal conduct in which the defendant has also participated, courts will not “decide, as between two scoundrels, who cheated whom the more.” Manning v Noa, 345 Mich 130, 133 ; 76 NW2d 75 (1956).

22004–2015

Where else courts name it

NY 48 (1917–2026) CA 28 (1942–2026) PA 12 (1950–2023) NC 10 (1984–2019) IL 10 (1979–2022) DE 10 (2004–2022) MI 9 (1996–2025) TX 7 (2006–2022) MA 7 (1870–2022) FL 5 (2007–2024) MD 5 (1992–2016) SD 4 (1988–2020) SC 4 (2006–2015) IN 4 (1980–2025) NJ 3 (1981–2021) LA 3 (1976–2022) MN 3 (1986–2007) MT 3 (1987–2019) OK 3 (1991–2014) NV 2 (2011–2011) WI 2 (2005–2008) CO 2 (2010–2012) NM 2 (1995–1995) MO 2 (1952–1998) AL 2 (2000–2014)

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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