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

8 Michigan opinions name it 2 courts 1997–2025 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 (11)

CaseFollowedCited
United States v. Mayesgreen
ca11 · 1998 · cited in 1 Michigan opinions naming this issue, 2023–2023
2 sentences

2023See, e.g., United States v Mayes, 158 F3d 1215, 1224 (CA 11, 1998) (“We have some flexibility in determining the extent that we choose to utilize the considerations enunciated in Kennedy for purposes of our double jeopardy analysis”), Porter v Coughlin, 421 F3d 141, 147 (CA 2, 2005) (“It is particularly appropriate to apply the factors flexibly in the context of prison discipline cases, which “do not fit neatly into the matrix of double jeopardy doctrine . . . because in the prison context, virtually any form of sanction seems ‘criminal’ and ‘punitive’ as we commonly understand those terms”),

2023See, e.g., United States v Mayes, 158 F3d 1215, 1224 (CA 11, 1998) (“We have some flexibility in determining the extent that we choose to utilize the considerations enunciated in Kennedy for purposes of our double jeopardy analysis”), Porter v Coughlin, 421 F3d 141, 147 (CA 2, 2005) (“It is particularly appropriate to apply the factors flexibly in the context of prison discipline cases, which “do not fit neatly into the matrix of double jeopardy doctrine . . . because in the prison context, virtually any form of sanction seems ‘criminal’ and ‘punitive’ as we commonly understand those terms”),

11
Haney v. United Statesgreen
dc · 2010 · cited in 1 Michigan opinions naming this issue, 2023–2023
2 sentences

2023Haney v United States, 999 A2d 48, 50 (DC App, 2010) (“federal circuits have held that most of the Hudson factors cannot be weighed equally in cases involving inmates because of the special circumstances inherent in a jail setting.

2023Haney v United States, 999 A2d 48, 50 (DC App, 2010) (“federal circuits have held that most of the Hudson factors cannot be weighed equally in cases involving inmates because of the special circumstances inherent in a jail setting.

11
Porter v. Coughlingreen
ca2 · 2005 · cited in 1 Michigan opinions naming this issue, 2023–2023
2 sentences

2023See, e.g., United States v Mayes, 158 F3d 1215, 1224 (CA 11, 1998) (“We have some flexibility in determining the extent that we choose to utilize the considerations enunciated in Kennedy for purposes of our double jeopardy analysis”), Porter v Coughlin, 421 F3d 141, 147 (CA 2, 2005) (“It is particularly appropriate to apply the factors flexibly in the context of prison discipline cases, which “do not fit neatly into the matrix of double jeopardy doctrine . . . because in the prison context, virtually any form of sanction seems ‘criminal’ and ‘punitive’ as we commonly understand those terms”),

2023See, e.g., United States v Mayes, 158 F3d 1215, 1224 (CA 11, 1998) (“We have some flexibility in determining the extent that we choose to utilize the considerations enunciated in Kennedy for purposes of our double jeopardy analysis”), Porter v Coughlin, 421 F3d 141, 147 (CA 2, 2005) (“It is particularly appropriate to apply the factors flexibly in the context of prison discipline cases, which “do not fit neatly into the matrix of double jeopardy doctrine . . . because in the prison context, virtually any form of sanction seems ‘criminal’ and ‘punitive’ as we commonly understand those terms”),

11
Tevis v. AMEX ASSURANCE CO.green
michctapp · 2009 · cited in 1 Michigan opinions naming this issue, 2019–2019
2 sentences

2019See Tevis v Amex Assurance Co, 283 Mich App 76 , 79- 80; 770 NW2d 16 (2009), in which this Court held that, in a priority dispute between two defendant insurers, the insurer held liable by the trial court to pay PIP benefits had suffered a particularized injury that affected its pecuniary interest, and it therefore was an aggrieved party under MCR 7.203(A) with respect to that ruling. -3- most favorable to the nonmoving party.

2019See Tevis v Amex Assurance Co, 283 Mich App 76 , 79- 80; 770 NW2d 16 (2009), in which this Court held that, in a priority dispute between two defendant insurers, the insurer held liable by the trial court to pay PIP benefits had suffered a particularized injury that affected its pecuniary interest, and it therefore was an aggrieved party under MCR 7.203(A) with respect to that ruling. -3- most favorable to the nonmoving party.

11
Hudson v. United Statesgreen
scotus · 1997 · cited in 1 Michigan opinions naming this issue, 2007–2007
2 sentences

2007Moreover, the Hudson factors “ ‘must be considered in relation to the statute on its face,’ and ‘only the clearest proof will suffice to override legislative intent....” Id. at 100 (citations omitted).

2007Moreover, the Hudson factors “ ‘must be considered in relation to the statute on its face,’ and ‘only the clearest proof will suffice to override legislative intent....” Id. at 100 (citations omitted).

11
cluster 7196green
· · cited in 1 Michigan opinions naming this issue, 1998–1998
1 sentence

1998Accord Hudson v. Palmer, 468 U.S. 517, 532-533 , 104 S.Ct. 3194 , 82 L.Ed.2d 393 (1984) (postdeprivation remedies do not satisfy due process where a deprivation of property is caused by conduct pursuant to established state [here municipal] procedure, rather than random and unauthorized action), Augustine v. Doe, 740 F.2d 322, 329 (C.A.5, 1984) ( Parratt v. Taylor, 451 U.S. 527 , 101 S.Ct. 1908 , 68 L.Ed.2d 420 [1981], applies only when the nature of the challenged conduct would render provision of predeprivation procedural safeguards impracticable or infeasible), and Alexander v. Ieyoub, 62 F

11
Francis Nolan Augustine v. John Doe, Deputy Sheriff, Lafayette Parishgreen
ca5 · 1984 · cited in 1 Michigan opinions naming this issue, 1998–1998
1 sentence

1998Accord Hudson v. Palmer, 468 U.S. 517, 532-533 , 104 S.Ct. 3194 , 82 L.Ed.2d 393 (1984) (postdeprivation remedies do not satisfy due process where a deprivation of property is caused by conduct pursuant to established state [here municipal] procedure, rather than random and unauthorized action), Augustine v. Doe, 740 F.2d 322, 329 (C.A.5, 1984) ( Parratt v. Taylor, 451 U.S. 527 , 101 S.Ct. 1908 , 68 L.Ed.2d 420 [1981], applies only when the nature of the challenged conduct would render provision of predeprivation procedural safeguards impracticable or infeasible), and Alexander v. Ieyoub, 62 F

11
Zinermon v. Burchgreen
scotus · 1990 · cited in 1 Michigan opinions naming this issue, 1998–1998
2 sentences

1998Zinermon appears to require predeprivation process in virtually all circumstances, see id. at 127-128 , 110 S.Ct. 975 (the Parratt/Hudson doctrine applies only in rare cases), but courts have struggled to apply its analysis consistently.

1998Zinermon appears to require predeprivation process in virtually all circumstances, see id. at 127-128 , 110 S.Ct. 975 (the Parratt/Hudson doctrine applies only in rare cases), but courts have struggled to apply its analysis consistently.

11
Hudson v. Palmergreen
scotus · 1984 · cited in 1 Michigan opinions naming this issue, 1998–1998
2 sentences

1998Accord Hudson v Palmer, 468 US 517, 532-533 ; 104 S Ct 3194 ; 82 L Ed 2d 393 (1984) (postdeprivation remedies do not satisfy due process where a deprivation of property is caused by conduct pursuant to established state [here municipal] procedure, rather than random and unauthorized action), Augustine v Doe, 740 F2d 322, 329 (CA 5, 1984) (Parratt v Taylor, 451 US 527 ; 101 S Ct 1908 ; 68 L Ed 2d 420 [1981], applies only when the nature of. the challenged conduct would render provision of predeprivation procedural safeguards impracticable or infeasible), and Alexander v Ieyoub, 62 F2d 709 (CA 5

1998Accord Hudson v Palmer, 468 US 517, 532-533 ; 104 S Ct 3194 ; 82 L Ed 2d 393 (1984) (postdeprivation remedies do not satisfy due process where a deprivation of property is caused by conduct pursuant to established state [here municipal] procedure, rather than random and unauthorized action), Augustine v Doe, 740 F2d 322, 329 (CA 5, 1984) (Parratt v Taylor, 451 US 527 ; 101 S Ct 1908 ; 68 L Ed 2d 420 [1981], applies only when the nature of. the challenged conduct would render provision of predeprivation procedural safeguards impracticable or infeasible), and Alexander v Ieyoub, 62 F2d 709 (CA 5

11
Parratt v. Taylorred
scotus · 1981 · cited in 1 Michigan opinions naming this issue, 1998–1998
2 sentences

1998Accord Hudson v Palmer, 468 US 517, 532-533 ; 104 S Ct 3194 ; 82 L Ed 2d 393 (1984) (postdeprivation remedies do not satisfy due process where a deprivation of property is caused by conduct pursuant to established state [here municipal] procedure, rather than random and unauthorized action), Augustine v Doe, 740 F2d 322, 329 (CA 5, 1984) (Parratt v Taylor, 451 US 527 ; 101 S Ct 1908 ; 68 L Ed 2d 420 [1981], applies only when the nature of. the challenged conduct would render provision of predeprivation procedural safeguards impracticable or infeasible), and Alexander v Ieyoub, 62 F2d 709 (CA 5

1998Accord Hudson v Palmer, 468 US 517, 532-533 ; 104 S Ct 3194 ; 82 L Ed 2d 393 (1984) (postdeprivation remedies do not satisfy due process where a deprivation of property is caused by conduct pursuant to established state [here municipal] procedure, rather than random and unauthorized action), Augustine v Doe, 740 F2d 322, 329 (CA 5, 1984) (Parratt v Taylor, 451 US 527 ; 101 S Ct 1908 ; 68 L Ed 2d 420 [1981], applies only when the nature of. the challenged conduct would render provision of predeprivation procedural safeguards impracticable or infeasible), and Alexander v Ieyoub, 62 F2d 709 (CA 5

11
Risner v. City of Wyominggreen
michctapp · 1985 · cited in 1 Michigan opinions naming this issue, 1997–1997
1 sentence

1997See Risner, supra at 434 .

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
Allstate Insurance Co v. State Farm Mutual Automobile Insurance Co green
michctapp · 2017
2 sentences

2025The trial court observed that, in Allstate Ins Co v State Farm Mut Auto Ins Co, 321 Mich App 543, 561-565 ; 909 NW2d 495 (2017), this Court reasoned that the statute of limitations generally applicable to claims for PIP benefits under MCL 500.3145 did not apply to the potential damages recoverable by an assigned insurer who seeks reimbursement from the highest priority insurer under MCL 500.3175.

2025The trial court observed that, in Allstate Ins Co v State Farm Mut Auto Ins Co, 321 Mich App 543, 561-565 ; 909 NW2d 495 (2017), this Court reasoned that the statute of limitations generally applicable to claims for PIP benefits under MCL 500.3145 did not apply to the potential damages recoverable by an assigned insurer who seeks reimbursement from the highest priority insurer under MCL 500.3175.

22025–2025
City of Cincinnati v. Discovery Network, Inc. green
scotus · 1993
2 sentences

1999Cincinnati v Discovery Network, Inc, 507 US 410, 416 ; 113 S Ct 1505 ; 123 L Ed 2d 99 (1993).

1999Cincinnati v Discovery Network, Inc, 507 US 410, 416 ; 113 S Ct 1505 ; 123 L Ed 2d 99 (1993).

11999–1999
Curtis W. Caine, Jr., M.D. v. Hardy, M.D., Woodie L. Mason green
ca5 · 1990
1 sentence

1998The alleged abuse of the ex parte mechanism in the PRCA amounts to an alleged failure to abide by the statutory safeguards or otherwise provide notice and a predeprivation hearing, see, e.g., MCR 3.310, thus stating a claim under ž 1983. [18] The Fifth Circuit's panel decision in Caine v. Hardy, 905 F.2d 858 (C.A.5, 1990) ( Caine I ), [19] is also instructive with regard to the debate over the limits of the Parratt/Hudson doctrine.

11998–1998
James E. Williams v. Keith Langston, Adrienne Johnson, L. Clarizio, and R. Farkas green
ca7 · 1997
2 sentences

1998Zinermon appears to require predeprivation process in virtually all circumstances, see id. at 127-128 , 110 S.Ct. 975 (the Parratt/Hudson doctrine applies only in rare cases), but courts have struggled to apply its analysis consistently.

1998Zinermon appears to require predeprivation process in virtually all circumstances, see id. at 127-128 , 110 S.Ct. 975 (the Parratt/Hudson doctrine applies only in rare cases), but courts have struggled to apply its analysis consistently.

11998–1998
Mathews v. Eldridge green
scotus · 1976
2 sentences

1998If it could, then the case requires classic Matthews [v Eldridge, 424 US 319 ; 96 S Ct 893 ; 47 L Ed 2d 18 (1976)] balancing and has stated a claim for relief.

1998If it could, then the case requires classic Matthews [v Eldridge, 424 US 319 ; 96 S Ct 893 ; 47 L Ed 2d 18 (1976)] balancing and has stated a claim for relief.

11998–1998
Central Hudson Gas & Electric Corp. v. Public Service Commission green
scotus · 1980
1 sentence

1997Id.

11997–1997

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 500.3101 (4) MI § Mich. Comp. Laws § 500.3114 (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

TX 38 (1998–2022) CA 29 (1984–2023) NY 23 (1928–2026) OH 22 (1996–2021) FL 13 (1983–2017) IL 12 (1983–2025) GA 10 (1979–2018) MO 9 (1986–2021) NJ 8 (1986–2021) MI 8 (1997–2025) MA 7 (1999–2021) WA 6 (1998–2005) IA 5 (1984–2025) AL 5 (1966–2023) ID 4 (2012–2026) MD 4 (1997–2015) RI 4 (1985–2007) AK 4 (2003–2016) NC 3 (1992–2013) DE 3 (1995–2020) PA 3 (1980–2017) KS 3 (2008–2020) MN 3 (1989–2011) DC 2 (1984–2010) NE 2 (2003–2005) TN 2 (1996–2016) IN 2 (1993–2016) AR 2 (1994–2017) ME 2 (2016–2018) NV 2 (1998–2000) WV 2 (1996–2021) AZ 2 (2005–2006) LA 2 (1992–2004)

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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