tolling doctrine (Michigan) · Go Syfert
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tolling doctrine in Michigan

9 Michigan opinions name it 2 courts 1976–2023 2 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 (4)

CaseFollowedCited
American Pipe & Construction Co. v. Utahgreen
scotus · 1974 · cited in 1 Michigan opinions naming this issue, 2006–2006
2 sentences

2006See, e.g., American Pipe & Constr Co v Utah, 414 US 538 ; 94 S Ct 756 ; 38 L Ed 2d 713 (1974), and Crown, Cork & Seal Co, Inc v Parker, 462 US 345 ; 103 S Ct 2392 ; 76 L Ed 2d 628 (1983).

2006See, e.g., American Pipe & Constr Co v Utah, 414 US 538 ; 94 S Ct 756 ; 38 L Ed 2d 713 (1974), and Crown, Cork & Seal Co, Inc v Parker, 462 US 345 ; 103 S Ct 2392 ; 76 L Ed 2d 628 (1983).

11
Patricia A. Weston v. Ameribankgreen
ca6 · 2001 · cited in 1 Michigan opinions naming this issue, 2006–2006
2 sentences

2006See Dressel, supra-, Weston, supra. I would follow the Sixth Circuit’s rule that the tolling doctrine applies only to substantive claims that were actually raised, or could have been raised, in the initial complaint. 5 Weston, supra at 368 .

2006See Dressel, supra-, Weston, supra. I would follow the Sixth Circuit’s rule that the tolling doctrine applies only to substantive claims that were actually raised, or could have been raised, in the initial complaint. 5 Weston, supra at 368 .

11
Dressel v. Ameribankgreen
mich · 2003 · cited in 1 Michigan opinions naming this issue, 2006–2006
1 sentence

2006See Dressel, supra-, Weston, supra. I would follow the Sixth Circuit’s rule that the tolling doctrine applies only to substantive claims that were actually raised, or could have been raised, in the initial complaint. 5 Weston, supra at 368 .

11
Johnson v. Railway Express Agency, Inc.green
scotus · 1975 · cited in 1 Michigan opinions naming this issue, 1976–1976
2 sentences

1976See Johnson v Railway Express Agency, Inc, 421 US 454,473 ; 95 S Ct 1716, 1726 ; 44 L Ed 2d 295,309 (1975) (Marshall, J., concurring in part and dissenting in part).

1976See Johnson v Railway Express Agency, Inc, 421 US 454,473 ; 95 S Ct 1716, 1726 ; 44 L Ed 2d 295,309 (1975) (Marshall, J., concurring in part and dissenting in part).

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 (6)

CaseCitedYears
Lewis v. Detroit Automobile Inter-Insurance Exchange red
mich · 1986
2 sentences

2023“Critically, the tolling exception adopted in MCL 500.3145(3) is identical to that embraced in the cases overruled, demonstrating the Legislature’s intent to impose a tolling exception to the one-year-back rule in the form it existed before Devillers.” Id. at ___; slip op at 7.

2005That condition, held the Court, would “alleviate the defendant’s fear that adoption of the tolling principle will result in ‘open-ended’ liability in cases in which the claimant, having made a specific claim for benefits, thereafter refuses to respond to the carrier’s legitimate requests for more information needed to process the claim.” Id. at 102-103 . 8 Further, it is nothing short of illogical not to require an insurer to deny a claim before imposing a restriction on what plaintiff can recover.

22005–2023
Richards v. American Fellowship Mutual Insurance green
michctapp · 1978
2 sentences

2022This Court first applied this tolling rule to former MCL 500.3145 in Richards v American Fellowship Mut Ins Co, 84 Mich App 629 ; 270 NW2d 670 (1978).3 See id. at 635 ([R]running of the 1 year statute of limitations was tolled from the day [the] plaintiff gave notice of loss . . . until liability was formally denied by [the] defendant. . . .”) (emphasis added).

2022This Court first applied this tolling rule to former MCL 500.3145 in Richards v American Fellowship Mut Ins Co, 84 Mich App 629 ; 270 NW2d 670 (1978).3 See id. at 635 ([R]running of the 1 year statute of limitations was tolled from the day [the] plaintiff gave notice of loss . . . until liability was formally denied by [the] defendant. . . .”) (emphasis added).

21982–2022
Allstate Insurance v. Frankenmuth Mutual Insurance neutral
michctapp · 1981
2 sentences

2006This was the Court of Appeals interpretation of the statute in Allstate Ins Co v Frankenmuth Mut Ins Co, 111 Mich App 617 ; 314 NW2d 711 (1981).

2006This was the Court of Appeals interpretation of the statute in Allstate Ins Co v Frankenmuth Mut Ins Co, 111 Mich App 617 ; 314 NW2d 711 (1981).

12006–2006
Tom Thomas Organization, Inc. v. Reliance Insurance green
mich · 1976
2 sentences

2006We relied on the tolling doctrine adopted by our Supreme Court in Tom Thomas Org, Inc v Reliance Ins Co, 396 Mich 588, 596-597 ; 242 NW2d 396 (1976), and held that limitations periods must be tolled from the time the insured gives notice of his or her claim until the insurer formally denies liability for the claim.

2006We relied on the tolling doctrine adopted by our Supreme Court in Tom Thomas Org, Inc v Reliance Ins Co, 396 Mich 588, 596-597 ; 242 NW2d 396 (1976), and held that limitations periods must be tolled from the time the insured gives notice of his or her claim until the insurer formally denies liability for the claim.

12006–2006
Crown, Cork & Seal Co. v. Parker green
scotus · 1983
2 sentences

2006See, e.g., American Pipe & Constr Co v Utah, 414 US 538 ; 94 S Ct 756 ; 38 L Ed 2d 713 (1974), and Crown, Cork & Seal Co, Inc v Parker, 462 US 345 ; 103 S Ct 2392 ; 76 L Ed 2d 628 (1983).

2006See, e.g., American Pipe & Constr Co v Utah, 414 US 538 ; 94 S Ct 756 ; 38 L Ed 2d 713 (1974), and Crown, Cork & Seal Co, Inc v Parker, 462 US 345 ; 103 S Ct 2392 ; 76 L Ed 2d 628 (1983).

12006–2006
Gagliardi v. Flack neutral
michctapp · 1989
2 sentences

1993Id. at 76 .

1993Id. at 76 .

11993–1993

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 500.3145 (6)

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

CA 69 (1974–2025) TX 60 (1992–2026) DE 24 (2009–2026) FL 17 (1986–2026) MD 15 (2005–2025) NY 14 (1990–2024) IL 12 (1993–2015) TN 11 (1998–2025) WI 11 (1988–2025) MI 9 (1976–2023) GA 9 (2006–2025) OK 7 (1959–2024) MA 7 (1988–2025) OH 7 (1978–2022) AK 6 (1984–2017) PA 6 (1985–1992) NJ 6 (1978–2025) DC 6 (1991–2000) NM 6 (1978–2025) CT 6 (1997–2019) NV 5 (2012–2019) IA 5 (2011–2024) IN 4 (1994–2015) WA 4 (1999–2023) AZ 4 (1996–2020) OR 4 (1997–2024) LA 3 (2010–2021) KY 3 (2009–2022) ID 3 (1993–2009) KS 3 (1984–2012) ME 3 (2010–2019) UT 3 (1999–2018) VA 2 (2017–2024) MT 2 (2014–2014) MN 2 (1984–2026) WV 2 (1997–2019) HI 2 (1998–2015) VT 2 (2005–2012) VI 2 (2000–2017)

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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