67 Michigan opinions name it 2 courts 1977–2026 19 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 |
|---|---|---|
Miller v. Chapman Contractinggreen2 sentences2025Under Michigan law, standing is a “limited, prudential” doctrine, intended “to assess whether a litigant’s interest in the issue is sufficient to ‘ensure sincere and vigorous advocacy.’ ” Lansing Sch Ed Ass’n v Lansing Bd of Ed, 487 Mich 13 Miller held that the plaintiff could not amend a complaint to add the proper real party in interest, the bankruptcy trustee, because “the relation-back doctrine does not apply to the addition of new parties.” Miller, 477 Mich at 106 (quotation marks, citations, and brackets omitted). 2025Under Michigan law, standing is a “limited, prudential” doctrine, intended “to assess whether a litigant’s interest in the issue is sufficient to ‘ensure sincere and vigorous advocacy.’ ” Lansing Sch Ed Ass’n v Lansing Bd of Ed, 487 Mich 13 Miller held that the plaintiff could not amend a complaint to add the proper real party in interest, the bankruptcy trustee, because “the relation-back doctrine does not apply to the addition of new parties.” Miller, 477 Mich at 106 (quotation marks, citations, and brackets omitted). | 6 | 21 |
Casserly v. Wayne Circuit Judgegreen2 sentences2016See Casserly v Wayne Circuit Judge, 124 Mich 157, 161 (1900), Prather Engineering Co v Detroit, F & S Ry Co, 152 Mich 582, 585 (1908); but see Miller v Chapman Contracting, 477 Mich 102, 105 (2007) (“the relation-back doctrine does not extend to the addition of new parties”). 2016See Casserly v Wayne Circuit Judge, 124 Mich 157, 161 (1900), Prather Engineering Co v Detroit, F & S Ry Co, 152 Mich 582, 585 (1908); but see Miller v Chapman Contracting, 477 Mich 102, 105 (2007) (“the relation-back doctrine does not extend to the addition of new parties”). | 3 | 3 |
Prather Engineering Co. v. Detroit, Flint & Saginaw Railwaygreen2 sentences2016See Casserly v Wayne Circuit Judge, 124 Mich 157, 161 (1900), Prather Engineering Co v Detroit, F & S Ry Co, 152 Mich 582, 585 (1908); but see Miller v Chapman Contracting, 477 Mich 102, 105 (2007) (“the relation-back doctrine does not extend to the addition of new parties”). 2016See Casserly v Wayne Circuit Judge, 124 Mich 157, 161 (1900), Prather Engineering Co v Detroit, F & S Ry Co, 152 Mich 582, 585 (1908); but see Miller v Chapman Contracting, 477 Mich 102, 105 (2007) (“the relation-back doctrine does not extend to the addition of new parties”). | 3 | 3 |
Local Emergency Financial Assistance Loan Board v. Blackwellgreen2 sentences2026“Whether the relation-back doctrine is applicable is a question of law that this Court reviews de novo.” Local Emergency Fin Assistance Loan Bd v Blackwell, 299 Mich App 727, 740-741 ; 832 NW2d 401 (2013). 2026“Whether the relation-back doctrine is applicable is a question of law that this Court reviews de novo.” Local Emergency Fin Assistance Loan Bd v Blackwell, 299 Mich App 727, 740-741 ; 832 NW2d 401 (2013). | 2 | 9 |
Jawad a Shah Md Pc v. State Farm Mutual Automobile Insurance Cogreen2 sentences2020In short, Spectrum only received the rights that Conley held in June 2017, and Spectrum “cannot rely on the relation-back doctrine to essentially gain the potential for a greater right to recovery than [it] actually received.” Id. at 205 . 2019Through the assignment, [the] plaintiffs only obtained the rights [assignor] actually held at the time of the execution of the assignment . . . and plaintiffs cannot rely on the relation-back doctrine to essentially gain the potential for a greater right to recovery than they actually received. [Shah, 324 Mich App at 204-205 .] Therefore, this Court concluded that the assignment of rights executed in favor of the plaintiffs only gave them the right to seek no-fault benefits for any portion of the loss that was incurred within one year of the date of assignment. | 2 | 8 |
Hurt v. Michael’s Food Center, Incgreen2 sentences2010This Court has previously held that “the relation-back doctrine does not extend to the addition of new parties.” Employers Mut Cas Co v Petroleum Equip, Inc, 190 Mich App 57, 63 ; 475 NW2d 418 (1991); see also Hurt v Michael’s Food Ctr, Inc, 220 Mich App 169, 179 ; 559 NW2d 660 (1996). 2010This Court has previously held that “the relation-back doctrine does not extend to the addition of new parties.” Employers Mut Cas Co v Petroleum Equip, Inc, 190 Mich App 57, 63 ; 475 NW2d 418 (1991); see also Hurt v Michael’s Food Ctr, Inc, 220 Mich App 169, 179 ; 559 NW2d 660 (1996). | 1 | 5 |
LaBar v. Coopergreen2 sentences2021And historically our Supreme Court has recognized that the relation-back doctrine serves an important and “functional” purpose, abjuring decision-making based on “technicalities.” LaBar v Cooper, 376 Mich 401, 407 ; 137 NW2d 136 (1965). 2021And historically our Supreme Court has recognized that the relation-back doctrine serves an important and “functional” purpose, abjuring decision-making based on “technicalities.” LaBar v Cooper, 376 Mich 401, 407 ; 137 NW2d 136 (1965). | 1 | 3 |
Forest v. Parmaleegreen2 sentences1982See Forest v Parmalee (On Rehearing), 60 Mich App 401, 406-407 ; 231 NW2d 378 (1975), aff'd 402 Mich 348 (1978). 1982See Forest v Parmalee (On Rehearing), 60 Mich App 401, 406-407 ; 231 NW2d 378 (1975), aff'd 402 Mich 348 (1978). | 1 | 2 |
Gladych v. New Family Homes, Incgreen2 sentences2025Plaintiff, however, omits the portion of Miller explicitly stating “the relation-back doctrine does not extend to the addition of new parties.” Id. -4- rules” or “[a]t the time jurisdiction over the defendant is otherwise acquired.” MCL 600.5856(a) and (b); see also Gladych v New Family Homes, Inc, 468 Mich 594, 599 ; 664 NW2d 705 (2003) (If a plaintiff “does not perform any actions specified by [MCL 600.5856], the statute of limitations is not tolled and therefore the period of limitations continues to run after the complaint has been filed.”). 2025Plaintiff, however, omits the portion of Miller explicitly stating “the relation-back doctrine does not extend to the addition of new parties.” Id. -4- rules” or “[a]t the time jurisdiction over the defendant is otherwise acquired.” MCL 600.5856(a) and (b); see also Gladych v New Family Homes, Inc, 468 Mich 594, 599 ; 664 NW2d 705 (2003) (If a plaintiff “does not perform any actions specified by [MCL 600.5856], the statute of limitations is not tolled and therefore the period of limitations continues to run after the complaint has been filed.”). | 1 | 1 |
Steven Iliades v. Dieffenbacher North America Incgreen1 sentence2022See id. | 1 | 1 |
| W a Foote Memorial Hospital v. Michigan Assigned Claims Plangreen | 1 | 1 |
| Rinke v. Automotive Moulding Co.green | 1 | 1 |
| Collucci v. Eklundgreen | 1 | 1 |
| Smith v. Henry Ford Hospitalgreen | 1 | 1 |
| Dewsnup v. Timm (In Re Dewsnup)green | 1 | 1 |
| Barletta v. Tedeschigreen | 1 | 1 |
| Maheras v. Awangreen | 1 | 1 |
| Shinkle v. Shinklegreen | 1 | 1 |
| Rory v. Continental Insurancegreen | 1 | 1 |
| Ben P. Fyke & Sons v. Gunter Co.green | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
Miller v. Chapman Contractinggreen2 sentences2025Under Michigan law, standing is a “limited, prudential” doctrine, intended “to assess whether a litigant’s interest in the issue is sufficient to ‘ensure sincere and vigorous advocacy.’ ” Lansing Sch Ed Ass’n v Lansing Bd of Ed, 487 Mich 13 Miller held that the plaintiff could not amend a complaint to add the proper real party in interest, the bankruptcy trustee, because “the relation-back doctrine does not apply to the addition of new parties.” Miller, 477 Mich at 106 (quotation marks, citations, and brackets omitted). 2025Under Michigan law, standing is a “limited, prudential” doctrine, intended “to assess whether a litigant’s interest in the issue is sufficient to ‘ensure sincere and vigorous advocacy.’ ” Lansing Sch Ed Ass’n v Lansing Bd of Ed, 487 Mich 13 Miller held that the plaintiff could not amend a complaint to add the proper real party in interest, the bankruptcy trustee, because “the relation-back doctrine does not apply to the addition of new parties.” Miller, 477 Mich at 106 (quotation marks, citations, and brackets omitted). | 3 | 21 |
| Case | Cited | Years |
|---|---|---|
Hayes-Albion Corp. v. Whiting Corp.
green
2 sentences2023See also Blackwell, 299 Mich App at 741 (stating the general rule that the relation-back doctrine does not extend to the addition of new parties and holding that there is an exception for new plaintiffs, where the defendant had notice of the interest of the person sought to be added as a plaintiff, and the new plaintiff’s claim arises out of the conduct); Hayes-Albion Corp v Whiting Corp, 184 Mich App 410, 418 , 459 NW2d 47 (1990) (providing the same).1 But this Court has recognized exceptions to that general rule where the original plaintiff puts a defendant on notice of the new party’s claim 2023See also Blackwell, 299 Mich App at 741 (stating the general rule that the relation-back doctrine does not extend to the addition of new parties and holding that there is an exception for new plaintiffs, where the defendant had notice of the interest of the person sought to be added as a plaintiff, and the new plaintiff’s claim arises out of the conduct); Hayes-Albion Corp v Whiting Corp, 184 Mich App 410, 418 , 459 NW2d 47 (1990) (providing the same).1 But this Court has recognized exceptions to that general rule where the original plaintiff puts a defendant on notice of the new party’s claim | 5 | 1997–2023 |
Employers Mutual Casualty Co. v. Petroleum Equipment, Inc.
green
2 sentences2010This Court has previously held that “the relation-back doctrine does not extend to the addition of new parties.” Employers Mut Cas Co v Petroleum Equip, Inc, 190 Mich App 57, 63 ; 475 NW2d 418 (1991); see also Hurt v Michael’s Food Ctr, Inc, 220 Mich App 169, 179 ; 559 NW2d 660 (1996). 2010This Court has previously held that “the relation-back doctrine does not extend to the addition of new parties.” Employers Mut Cas Co v Petroleum Equip, Inc, 190 Mich App 57, 63 ; 475 NW2d 418 (1991); see also Hurt v Michael’s Food Ctr, Inc, 220 Mich App 169, 179 ; 559 NW2d 660 (1996). | 5 | 1997–2010 |
Jones v. Chambers
green
2 sentences2019As our Supreme Court explained in Jones v Chambers, 353 Mich 674, 681-682 ; 91 NW2d 889 (1958): “The assignment created nothing. 2019As our Supreme Court explained in Jones v Chambers, 353 Mich 674, 681-682 ; 91 NW2d 889 (1958): “The assignment created nothing. | 4 | 2018–2019 |
Burkhardt v. Bailey
green
2 sentences2019Through the assignment, plaintiffs only obtained the rights Hensley actually held at the time of the execution of the assignment, Burkhardt, 260 Mich App at 652-653 , and plaintiffs cannot rely on the relation-back doctrine to essentially gain the potential for a greater right to recovery than they actually received. 2018Through the assignment, plaintiffs only obtained the rights Hensley actually held at the time of the execution of the assignment, Burkhardt , 260 Mich.App. at 652 -653 , 680 N.W.2d 453 , and plaintiffs cannot rely on the relation-back doctrine to essentially gain the potential for a greater right to recovery than they actually received. | 4 | 2018–2019 |
Castle v. Lockwood-MacDonald Hospital
green
2 sentences2024Though the language of the statute provides an appointment as administrator after the period of limitations has expired relates back to the filing of suit if, at the time the suit was filed the plaintiff holds a good faith reasonable belief that he has authority to bring suit as administrator, provided that the defendant is not prejudiced by the application of the relation-back doctrine in such situations”); Warren v Howlett, 148 Mich App 417, 422-423 ; 383 NW2d 636 (1986); Fisher v Volkswagenwerk Aktiengesellschaft, 115 Mich App 781, 786 ; 321 NW2d 814 (1982) (appointment as personal represen 2024Though the language of the statute provides an appointment as administrator after the period of limitations has expired relates back to the filing of suit if, at the time the suit was filed the plaintiff holds a good faith reasonable belief that he has authority to bring suit as administrator, provided that the defendant is not prejudiced by the application of the relation-back doctrine in such situations”); Warren v Howlett, 148 Mich App 417, 422-423 ; 383 NW2d 636 (1986); Fisher v Volkswagenwerk Aktiengesellschaft, 115 Mich App 781, 786 ; 321 NW2d 814 (1982) (appointment as personal represen | 3 | 1986–2024 |
Fisher v. Volkswagenwerk Aktiengesellschaft
green
2 sentences2024Though the language of the statute provides an appointment as administrator after the period of limitations has expired relates back to the filing of suit if, at the time the suit was filed the plaintiff holds a good faith reasonable belief that he has authority to bring suit as administrator, provided that the defendant is not prejudiced by the application of the relation-back doctrine in such situations”); Warren v Howlett, 148 Mich App 417, 422-423 ; 383 NW2d 636 (1986); Fisher v Volkswagenwerk Aktiengesellschaft, 115 Mich App 781, 786 ; 321 NW2d 814 (1982) (appointment as personal represen 2024Though the language of the statute provides an appointment as administrator after the period of limitations has expired relates back to the filing of suit if, at the time the suit was filed the plaintiff holds a good faith reasonable belief that he has authority to bring suit as administrator, provided that the defendant is not prejudiced by the application of the relation-back doctrine in such situations”); Warren v Howlett, 148 Mich App 417, 422-423 ; 383 NW2d 636 (1986); Fisher v Volkswagenwerk Aktiengesellschaft, 115 Mich App 781, 786 ; 321 NW2d 814 (1982) (appointment as personal represen | 3 | 1986–2024 |
Doyle v. Hutzel Hospital
green
2 sentences2024Under the relation-back doctrine, an “amended pleading can introduce new facts, new theories, or even a different cause of action as long as the amendment arises from the same transactional setting that was set forth in the original pleading.” Doyle, 241 Mich App at 212-213 . 2024“The principle to be gleaned . . . is the necessity for a broadly focused inquiry regarding whether the allegations in the original and amended pleadings stem from the same general ‘conduct, transaction, or occurrence.’ ” Id. at 219 . | 3 | 2001–2024 |
Grist v. the Upjohn Company
green
2 sentences2021This conclusion rested on dicta from a case decided in 1965, Grist v Upjohn Co, 1 Mich App 72, 84 ; 134 NW2d 358 (1965), noting that in the court rules “there is no provision for relating back as to supplemental pleadings . . . .” The relation-back doctrine was immaterial to this Court’s decision in Grist. 2021This conclusion rested on dicta from a case decided in 1965, Grist v Upjohn Co, 1 Mich App 72, 84 ; 134 NW2d 358 (1965), noting that in the court rules “there is no provision for relating back as to supplemental pleadings . . . .” The relation-back doctrine was immaterial to this Court’s decision in Grist. | 3 | 2018–2021 |
American Pipe & Construction Co. v. Utah
green
2 sentences2006Additionally, the Court of Appeals demonstrated that it applied the relation-back doctrine only when it stated: Both defendant and the trial court interpret the ruling in American Pipe [& Constr Co v Utah, 414 US 538 ; 94 S Ct 756 ; 38 L Ed 2d 713 (1974)] to require notification of specific causes of action before the period of limitations on those claims expires. 2006Additionally, the Court of Appeals demonstrated that it applied the relation-back doctrine only when it stated: Both defendant and the trial court interpret the ruling in American Pipe [& Constr Co v Utah, 414 US 538 ; 94 S Ct 756 ; 38 L Ed 2d 713 (1974)] to require notification of specific causes of action before the period of limitations on those claims expires. | 3 | 2004–2007 |
People v. Mungo
green
2 sentences2025Though the Court also made various statements about the real party in interest rule, such as describing it as a “standing doctrine,” see id. at 106-107 , these comments were neither “necessarily involved nor essential to determination of the case in hand” and thus were dicta, Wold Architects & Engineers v Strat, 474 Mich 223 , 232 n 3; 713 NW2d 750 (2006) (quotation marks and citations omitted). 17 349, 355; 792 NW2d 686 (2010) (LSEA). 2025Though the Court also made various statements about the real party in interest rule, such as describing it as a “standing doctrine,” see id. at 106-107 , these comments were neither “necessarily involved nor essential to determination of the case in hand” and thus were dicta, Wold Architects & Engineers v Strat, 474 Mich 223 , 232 n 3; 713 NW2d 750 (2006) (quotation marks and citations omitted). 17 349, 355; 792 NW2d 686 (2010) (LSEA). | 2 | 2025–2025 |
Wold Architects and Engineers v. Strat
green
2 sentences2025Though the Court also made various statements about the real party in interest rule, such as describing it as a “standing doctrine,” see id. at 106-107 , these comments were neither “necessarily involved nor essential to determination of the case in hand” and thus were dicta, Wold Architects & Engineers v Strat, 474 Mich 223 , 232 n 3; 713 NW2d 750 (2006) (quotation marks and citations omitted). 17 349, 355; 792 NW2d 686 (2010) (LSEA). 2025Though the Court also made various statements about the real party in interest rule, such as describing it as a “standing doctrine,” see id. at 106-107 , these comments were neither “necessarily involved nor essential to determination of the case in hand” and thus were dicta, Wold Architects & Engineers v Strat, 474 Mich 223 , 232 n 3; 713 NW2d 750 (2006) (quotation marks and citations omitted). 17 349, 355; 792 NW2d 686 (2010) (LSEA). | 2 | 2025–2025 |
Doan v. Chesapeake & Ohio Railway Co.
green
2 sentences2024Though the language of the statute provides an appointment as administrator after the period of limitations has expired relates back to the filing of suit if, at the time the suit was filed the plaintiff holds a good faith reasonable belief that he has authority to bring suit as administrator, provided that the defendant is not prejudiced by the application of the relation-back doctrine in such situations”); Warren v Howlett, 148 Mich App 417, 422-423 ; 383 NW2d 636 (1986); Fisher v Volkswagenwerk Aktiengesellschaft, 115 Mich App 781, 786 ; 321 NW2d 814 (1982) (appointment as personal represen 2024Though the language of the statute provides an appointment as administrator after the period of limitations has expired relates back to the filing of suit if, at the time the suit was filed the plaintiff holds a good faith reasonable belief that he has authority to bring suit as administrator, provided that the defendant is not prejudiced by the application of the relation-back doctrine in such situations”); Warren v Howlett, 148 Mich App 417, 422-423 ; 383 NW2d 636 (1986); Fisher v Volkswagenwerk Aktiengesellschaft, 115 Mich App 781, 786 ; 321 NW2d 814 (1982) (appointment as personal represen | 2 | 1986–2024 |
Salem Springs, LLC v. Salem Township
green
2 sentences2023See Miller v Chapman Contracting, 477 Mich 102, 106-108 ; 730 NW2d 462 (2007); Salem Springs, LLC v Salem Twp, 312 Mich App 210, 222-224 ; 880 NW2d 793 (2015). 2020Salem Springs, 312 Mich App at 221-224 . | 2 | 2020–2023 |
Davis v. Department of Corrections
green
2 sentences2017Id. at 376 . 2017Id. at 376 . | 2 | 2017–2017 |
Maiden v. Rozwood
green
1 sentence2026Id. | 1 | 2026–2026 |
Kearns v. Michigan Iron & Coke Co.
green
1 sentence2025Id. | 1 | 2025–2025 |
Warren v. Howlett
green
2 sentences2024Though the language of the statute provides an appointment as administrator after the period of limitations has expired relates back to the filing of suit if, at the time the suit was filed the plaintiff holds a good faith reasonable belief that he has authority to bring suit as administrator, provided that the defendant is not prejudiced by the application of the relation-back doctrine in such situations”); Warren v Howlett, 148 Mich App 417, 422-423 ; 383 NW2d 636 (1986); Fisher v Volkswagenwerk Aktiengesellschaft, 115 Mich App 781, 786 ; 321 NW2d 814 (1982) (appointment as personal represen 2024Though the language of the statute provides an appointment as administrator after the period of limitations has expired relates back to the filing of suit if, at the time the suit was filed the plaintiff holds a good faith reasonable belief that he has authority to bring suit as administrator, provided that the defendant is not prejudiced by the application of the relation-back doctrine in such situations”); Warren v Howlett, 148 Mich App 417, 422-423 ; 383 NW2d 636 (1986); Fisher v Volkswagenwerk Aktiengesellschaft, 115 Mich App 781, 786 ; 321 NW2d 814 (1982) (appointment as personal represen | 1 | 2024–2024 |
Davis v. State Employees' Retirement Board
green
2 sentences2023“Questions regarding statutory construction and whether a statute or amended statute should be applied retroactively or prospectively only are reviewed de novo.” Davis v State Employees’ Retirement Bd, 272 Mich App 151, 152-153 ; 725 NW2d 56 (2006). 2023“Questions regarding statutory construction and whether a statute or amended statute should be applied retroactively or prospectively only are reviewed de novo.” Davis v State Employees’ Retirement Bd, 272 Mich App 151, 152-153 ; 725 NW2d 56 (2006). | 1 | 2023–2023 |
Pontiac Police & Fire Retiree Prefunded Group Health & Insurance Trust Board of Trustees v. City of Pontiac No 2
green
2 sentences2023“The “issue of whether a plaintiff is the real party in interest is also a question of law that we review de novo.” Pontiac Police & Fire Prefunded Group Health & Ins Trust Bd of Trustees v Pontiac No 2, 309 Mich App 611, 621 ; 873 NW2d 783 (2015). 2023“The “issue of whether a plaintiff is the real party in interest is also a question of law that we review de novo.” Pontiac Police & Fire Prefunded Group Health & Ins Trust Bd of Trustees v Pontiac No 2, 309 Mich App 611, 621 ; 873 NW2d 783 (2015). | 1 | 2023–2023 |
Teddy 23, LLC v. Michigan Film Office
green
1 sentence2022Teddy 23, LLC v Mich Film Office, 313 Mich App 557, 570-571 ; 884 NW2d 799 (2015); Local Emergency Fin Assistance Loan Bd v Blackwell, 299 Mich App 727, 740-741 ; 832 NW2d 401 (2013). | 1 | 2022–2022 |
| Bint v. Doe green | 1 | 2019–2019 |
| Bint v. Doe green | 1 | 2019–2019 |
| Darryl McGore v. Baraga Correctional Facility Warden green | 1 | 2019–2019 |
| Wells Fargo Bank v. Country Place Condominium Ass'n green | 1 | 2016–2016 |
| Flint & Pere Marquette Railway Co. v. Gordon green | 1 | 2016–2016 |
| Tice Estate v. Tice green | 1 | 2014–2014 |
| General Motors Corp. v. Department of Treasury green | 1 | 2014–2014 |
| Dunitz v. Woodford Apartments Co. green | 1 | 2014–2014 |
| Whipple v. Farrar green | 1 | 2014–2014 |
| Clark v. Hall green | 1 | 2014–2014 |
| Vushaj v. Farm Bureau General Insurance green | 1 | 2014–2014 |
| Stamp v. Mill Street Inn green | 1 | 2010–2010 |
| Blue Cross & Blue Shield v. Eaton Rapids Community Hospital green | 1 | 2007–2007 |
| Tiller v. Atlantic Coast Line Railroad green | 1 | 2007–2007 |
| Cowles v. Bank West green | 1 | 2007–2007 |
| Cowles v. Bank West green | 1 | 2006–2006 |
| Devlin v. Scardelletti green | 1 | 2004–2004 |
| Yudashkin v. Holden green | 1 | 2004–2004 |
| Colista v. Thomas green | 1 | 2001–2001 |
| Hoste v. Shanty Creek Management, Inc green | 1 | 2001–2001 |
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.