50 Michigan opinions name it 2 courts 1953–2025 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.
| Case | Followed | Cited |
|---|---|---|
Pittsfield Charter Township v. Washtenaw Countygreen2 sentences2023Pursuant to “the doctrine of expressio unius est exclusio alterius,” meaning “the expression of one thing suggests the exclusion of all others,” Pittsfield Charter Twp v Washtenaw Co, 468 Mich. 702, 712 ; 664 NW2d 193 (2003), the fact that the Legislature explicitly provided a single situation in which contempt proceedings may be heard before a different court strongly suggests that contempt proceedings may not otherwise be held before a different court. 2023Pursuant to “the doctrine of expressio unius est exclusio alterius,” meaning “the expression of one thing suggests the exclusion of all others,” Pittsfield Charter Twp v Washtenaw Co, 468 Mich. 702, 712 ; 664 NW2d 193 (2003), the fact that the Legislature explicitly provided a single situation in which contempt proceedings may be heard before a different court strongly suggests that contempt proceedings may not otherwise be held before a different court. | 4 | 8 |
Jawad a Shah Md Pc v. State Farm Mutual Automobile Insurance Cogreen2 sentences2020By not including past-due benefits in this statutory prohibition, the Legislature, under the doctrine of expressio unius est exclusio alterius, made clear its intent to adhere to the fundamental principle that assignments of past-due benefits are effective and proper. [Shah, 324 Mich App at 216 (SHAPIRO, J., concurring in part and dissenting in part).] It is a misapplication of the expressio unius maxim to conclude that the Legislature must have intended by implication to render invalid all anti-assignment provisions. 2019While plaintiff also alleged that defendant breached its contractual duties pursuant to the contract, there is no contract between Allen, the injured party, and defendant, the responsible insurer. -4- Legislature is presumed to have intended the meaning that a statute plainly expresses. [Id. (citation omitted).] See also Shah, 324 Mich App at 216 (SHAPIRO, J., concurring in part and dissenting in part) (“By not including past-due benefits in this statutory prohibition, the Legislature, under the doctrine of expressio unius est exclusio alterius, made clear its intent to adhere to the fundament | 3 | 3 |
In re AJRgreen2 sentences2015Hackel v Macomb Co Comm, 298 Mich App 311, 324 ; 826 NW2d 753 (2012) (explaining that “the doctrine of expressio unius est exclusio alterius” means “inclusion by specific mention excludes what is not mentioned”) (citation and quotation marks omitted); see also In re AJR, 300 Mich App 597, 600 ; 834 NW2d 904 (2013) (“[T]his Court may not ignore the omission of a term from one section of a statute when that term is used in another section of the statute.”). 2015Hackel v Macomb Co Comm, 298 Mich App 311, 324 ; 826 NW2d 753 (2012) (explaining that “the doctrine of expressio unius est exclusio alterius” means “inclusion by specific mention excludes what is not mentioned”) (citation and quotation marks omitted); see also In re AJR, 300 Mich App 597, 600 ; 834 NW2d 904 (2013) (“[T]his Court may not ignore the omission of a term from one section of a statute when that term is used in another section of the statute.”). | 3 | 3 |
Detroit City Council v. Mayor of Detroitgreen2 sentences2025THE SLI DRAWING’S REQUIREMENTS 4 The doctrine of expressio unius est exclusio alterius (the expression of one thing is the exclusion of another) “has been described as a rule of construction that is a product of logic and common sense.” Detroit City Council v Detroit Mayor, 283 Mich App 442, 456 ; 770 NW2d 117 (2009) (quotation marks and citation omitted). 2025THE SLI DRAWING’S REQUIREMENTS 4 The doctrine of expressio unius est exclusio alterius (the expression of one thing is the exclusion of another) “has been described as a rule of construction that is a product of logic and common sense.” Detroit City Council v Detroit Mayor, 283 Mich App 442, 456 ; 770 NW2d 117 (2009) (quotation marks and citation omitted). | 2 | 5 |
Hackel v. Macomb County Commissiongreen2 sentences2015Hackel v Macomb Co Comm, 298 Mich App 311, 324 ; 826 NW2d 753 (2012) (explaining that “the doctrine of expressio unius est exclusio alterius” means “inclusion by specific mention excludes what is not mentioned”) (citation and quotation marks omitted); see also In re AJR, 300 Mich App 597, 600 ; 834 NW2d 904 (2013) (“[T]his Court may not ignore the omission of a term from one section of a statute when that term is used in another section of the statute.”). 2015Hackel v Macomb Co Comm, 298 Mich App 311, 324 ; 826 NW2d 753 (2012) (explaining that “the doctrine of expressio unius est exclusio alterius” means “inclusion by specific mention excludes what is not mentioned”) (citation and quotation marks omitted); see also In re AJR, 300 Mich App 597, 600 ; 834 NW2d 904 (2013) (“[T]his Court may not ignore the omission of a term from one section of a statute when that term is used in another section of the statute.”). | 2 | 3 |
Williams v. Mayor of Detroitgreen2 sentences2018The doctrine of expressio unius est exclusio alterius has long been recognized in this State: that “the expression of one thing suggests the exclusion of all others.” People v Wilson, 500 Mich 521 , 526; 902 NW2d 378 (2017); Williams v Mayor, Etc., of Detroit, 2 Mich 560, 563 (1853)3; Pine Grove Twp v Talcott, 86 US (19 Wall) 666, 674-675; 22 LEd 227 (1873). 2018The doctrine of expressio unius est exclusio alterius has long been recognized in this state: that "the expression of one thing suggests the exclusion of all others." People v. Wilson , 500 Mich. 521 , 526, 902 N.W.2d 378 (2017) ; Williams v. Mayor, &c., of Detroit , 2 Mich. 560 , 563 (1853) 3 ; Pine Grove Twp. v. Talcott , 86 U.S. (19 Wall). 666, 674-675, 22 L Ed 227 (1873). | 1 | 3 |
Wayne County v. Wayne County Retirement Commissiongreen2 sentences2015See Wayne Co v Wayne Co Retirement Comm, 267 Mich App 230, 248 ; 704 NW2d 117 (2005) (“A general principle of . . . construction is the doctrine of expressio unius est exclusio alterius, which means the express mention of one thing implies the exclusion of another.”). 2015See Wayne Co v Wayne Co Retirement Comm, 267 Mich App 230, 248 ; 704 NW2d 117 (2005) (“A general principle of . . . construction is the doctrine of expressio unius est exclusio alterius, which means the express mention of one thing implies the exclusion of another.”). | 1 | 2 |
Darryl McGore v. Baraga Correctional Facility Wardengreen1 sentence2018See also Shah , 324 Mich. App. at 216 , 920 N.W.2d 148 ( SHAPIRO , J., concurring in part and dissenting in part) ("By not including past-due benefits in this statutory prohibition, the Legislature, under the doctrine of expressio unius est exclusio alterius , made clear its intent to adhere to the fundamental principle that assignments of past-due benefits are effective and proper."). | 1 | 1 |
City of Detroit v. Walkergreen1 sentence2015However, in construing Const 1963, art 7, § 22 and Const 1963, art 7, § 34, the Michigan Supreme Court ruled that “home rule cities enjoy not only those powers specifically granted, but they may also exercise all powers not expressly denied.” Walker, 445 Mich at 690 (emphasis added). | 1 | 1 |
Luttrell v. Department of Correctionsgreen2 sentences2008See Luttrell v Dep’t of Corrections, 421 Mich 93, 107 ; 365 NW2d 74 (1984). 2008See Luttrell v Dep’t of Corrections, 421 Mich 93, 107 ; 365 NW2d 74 (1984). | 1 | 1 |
| Rowell v. Security Steel Processing Co.green | 1 | 1 |
| Feld v. Robert & Charles Beauty Salongreen | 1 | 1 |
| People v. Langegreen | 1 | 1 |
| Chesapeake & Ohio Railway Co. v. Public Service Commissiongreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Michigan. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Jahner
green
2 sentences2017The application of the canon of statutory interpretation expressio unius est exclusio alterius 2 directs us to read this absence as 2 “[T]he doctrine of expressio unius est exclusio alterius . . . provides that ‘the express mention in a statute of one thing implies the exclusion of other similar things.’ ” People v Feeley, 499 Mich 429, 438-439 ; 885 NW2d 223 (2016), quoting People v Jahner, 433 Mich 490 , 500 n 3; 446 NW2d 151 (1989). 8 meaningful, especially in light of the lack of any language that would suggest that this was intended to be an illustrative, rather than an exclusionary, list 2017The application of the canon of statutory interpretation expressio unius est exclusio alterius 2 directs us to read this absence as 2 “[T]he doctrine of expressio unius est exclusio alterius . . . provides that ‘the express mention in a statute of one thing implies the exclusion of other similar things.’ ” People v Feeley, 499 Mich 429, 438-439 ; 885 NW2d 223 (2016), quoting People v Jahner, 433 Mich 490 , 500 n 3; 446 NW2d 151 (1989). 8 meaningful, especially in light of the lack of any language that would suggest that this was intended to be an illustrative, rather than an exclusionary, list | 4 | 2016–2023 |
Tuggle v. Department of State Police
green
2 sentences2020Further buttressing this conclusion is the doctrine of expressio unius est exclusio alterius, which is “the maxim that the expression of one thing means the exclusion of another . . . .” Tuggle v Dept of State Police, 269 Mich App 657, 663 ; 712 NW2d 750 (2005). 2020Further buttressing this conclusion is the doctrine of expressio unius est exclusio alterius, which is “the maxim that the expression of one thing means the exclusion of another . . . .” Tuggle v Dept of State Police, 269 Mich App 657, 663 ; 712 NW2d 750 (2005). | 3 | 2008–2020 |
Midamerican Energy Company v. Department of Treasury
green
2 sentences2020MidAmerican Energy Co v Dep't of Treasury, 308 Mich App 362, 370 ; 863 NW2d 387 (2014) (citation and quotations omitted) (“A general principle of statutory construction is the doctrine of expressio unius est exclusio alterius, which means the express mention of one thing implies the exclusion of another.”) By this same logic, that the Legislature expressly gave Treasury a limited role as a depository and collection agent implies that the Legislature did not intend to grant Treasury the expansive powers it possesses under the Revenue Act with respect to the QAA. 2016League General Insurance 5 “[T]he doctrine of expressio unius est exclusio alterius . . . means the express mention of one thing implies the exclusion of another.” MidAmerican Energy Co v Dep’t of Treasury, 308 Mich App 362, 370 ; 863 NW2d 387 (2014). -8- Our Supreme Court’s holding in League Gen Ins, 435 Mich at 338 does not alter our conclusion that the MCCA is a public body for purposes of FOIA. | 2 | 2016–2020 |
Township of Pine Grove v. Talcott
green
2 sentences2018The doctrine of expressio unius est exclusio alterius has long been recognized in this State: that “the expression of one thing suggests the exclusion of all others.” People v Wilson, 500 Mich 521 , 526; 902 NW2d 378 (2017); Williams v Mayor, Etc., of Detroit, 2 Mich 560, 563 (1853)3; Pine Grove Twp v Talcott, 86 US (19 Wall) 666, 674-675; 22 LEd 227 (1873). 2018The doctrine of expressio unius est exclusio alterius has long been recognized in this state: that "the expression of one thing suggests the exclusion of all others." People v. Wilson , 500 Mich. 521 , 526, 902 N.W.2d 378 (2017) ; Williams v. Mayor, &c., of Detroit , 2 Mich. 560 , 563 (1853) 3 ; Pine Grove Twp. v. Talcott , 86 U.S. (19 Wall). 666, 674-675, 22 L Ed 227 (1873). | 2 | 2018–2018 |
People v. Feeley
green
2 sentences2017The application of the canon of statutory interpretation expressio unius est exclusio alterius 2 directs us to read this absence as 2 “[T]he doctrine of expressio unius est exclusio alterius . . . provides that ‘the express mention in a statute of one thing implies the exclusion of other similar things.’ ” People v Feeley, 499 Mich 429, 438-439 ; 885 NW2d 223 (2016), quoting People v Jahner, 433 Mich 490 , 500 n 3; 446 NW2d 151 (1989). 8 meaningful, especially in light of the lack of any language that would suggest that this was intended to be an illustrative, rather than an exclusionary, list 2017The application of the canon of statutory interpretation expressio unius est exclusio alterius 2 directs us to read this absence as 2 “[T]he doctrine of expressio unius est exclusio alterius . . . provides that ‘the express mention in a statute of one thing implies the exclusion of other similar things.’ ” People v Feeley, 499 Mich 429, 438-439 ; 885 NW2d 223 (2016), quoting People v Jahner, 433 Mich 490 , 500 n 3; 446 NW2d 151 (1989). 8 meaningful, especially in light of the lack of any language that would suggest that this was intended to be an illustrative, rather than an exclusionary, list | 2 | 2017–2017 |
Dave's Place, Inc. v. Liquor Control Comm.
green
2 sentences2013Pittsfield Charter Twp v Washtenaw Co, 468 Mich 702, 712 ; 664 NW2d 193 (2003); Dave’s Place, Inc v Liquor Control Comm, 277 Mich 551 ; 269 NW 594 (1936); Detroit v Redford Twp, 253 Mich 453, 455-456 ; 235 NW 217 (1931). 35 Rahman, 245 Mich App at 121 . 14 reasons” has no effect on the employer’s obligation to pay weekly benefits under the law.36 C. 2013Pittsfield Charter Twp v Washtenaw Co, 468 Mich 702, 712 ; 664 NW2d 193 (2003); Dave’s Place, Inc v Liquor Control Comm, 277 Mich 551 ; 269 NW 594 (1936); Detroit v Redford Twp, 253 Mich 453, 455-456 ; 235 NW 217 (1931). 35 Rahman, 245 Mich App at 121 . 14 reasons” has no effect on the employer’s obligation to pay weekly benefits under the law.36 C. | 2 | 2003–2013 |
Stowers v. Wolodzko
green
2 sentences1999The conclusion that the subsection supersedes the common law is based on the doctrine of expressio unius est exclusio alterius (“express mention in a statute of one thing implies the exclusion of other similar things.” Stowers v Wolodzko, 386 Mich 119, 133 ; 191 NW2d 355 [1971]). 1999The conclusion that the subsection supersedes the common law is based on the doctrine of expressio unius est exclusio alterius (“express mention in a statute of one thing implies the exclusion of other similar things.” Stowers v Wolodzko, 386 Mich 119, 133 ; 191 NW2d 355 [1971]). | 2 | 1988–1999 |
Smitter v. Thornapple Township
green
2 sentences2022“Under the doctrine of expressio unius est exclusio alterius (the expression of one thing is the exclusion of another), the specification in a statute of one particular class excludes all other classes.” Smitter v Thornapple Twp, 494 Mich 121 , 137 n 34; 833 NW2d 875 (2013). 2022“Under the doctrine of expressio unius est exclusio alterius (the expression of one thing is the exclusion of another), the specification in a statute of one particular class excludes all other classes.” Smitter v Thornapple Twp, 494 Mich 121 , 137 n 34; 833 NW2d 875 (2013). | 1 | 2022–2022 |
Coventry Parkhomes Condominium Ass'n v. Federal National Mortgage Ass'n
green
1 sentence2021Id. | 1 | 2021–2021 |
Barnhart v. Peabody Coal Co.
green
2 sentences2020The maxim expressio unius est exclusio alterius (the expression of one thing is the exclusion of another),5 “has force only when the items expressed are members of an associated group or series, justifying the inference that items not mentioned were excluded by deliberate choice, not inadvertence.” Esurance Prop & Cas Ins Co v Michigan Assigned Claims Plan, ___Mich App ___, ___; ___ NW2d ___ (2019) (Docket No. 344715), quoting Barnhart v Peabody Coal Co, 537 US 149, 168 ; 123 S Ct 748 ; 154 L Ed 2d 653 (2003) (internal quotation marks omitted). 2020The maxim expressio unius est exclusio alterius (the expression of one thing is the exclusion of another),5 “has force only when the items expressed are members of an associated group or series, justifying the inference that items not mentioned were excluded by deliberate choice, not inadvertence.” Esurance Prop & Cas Ins Co v Michigan Assigned Claims Plan, ___Mich App ___, ___; ___ NW2d ___ (2019) (Docket No. 344715), quoting Barnhart v Peabody Coal Co, 537 US 149, 168 ; 123 S Ct 748 ; 154 L Ed 2d 653 (2003) (internal quotation marks omitted). | 1 | 2020–2020 |
Hoste v. Shanty Creek Management, Inc
green
2 sentences2020Generally speaking, the doctrine of expressio unius est exclusio alterius (“express mention in a statute of one thing implies the exclusion of other similar things”) would exclude the EPGA from the inclusion in the collective “statutes.” Hoste v Shanty Creek Mgt, Inc, 459 Mich 561, 572 , 592 NW2d 360 (1999). 2020Generally speaking, the doctrine of expressio unius est exclusio alterius (“express mention in a statute of one thing implies the exclusion of other similar things”) would exclude the EPGA from the inclusion in the collective “statutes.” Hoste v Shanty Creek Mgt, Inc, 459 Mich 561, 572 , 592 NW2d 360 (1999). | 1 | 2020–2020 |
In Re MCI Telecommunications Complaint
green
2 sentences2016In re MCI Telecom Complaint, 460 Mich 396, 415 ; 596 NW2d 164 (1999). 2016In re MCI Telecom Complaint, 460 Mich 396, 415 ; 596 NW2d 164 (1999). | 1 | 2016–2016 |
League General Insurance v. Michigan Catastrophic Claims Ass'n
green
1 sentence2016League General Insurance 5 “[T]he doctrine of expressio unius est exclusio alterius . . . means the express mention of one thing implies the exclusion of another.” MidAmerican Energy Co v Dep’t of Treasury, 308 Mich App 362, 370 ; 863 NW2d 387 (2014). -8- Our Supreme Court’s holding in League Gen Ins, 435 Mich at 338 does not alter our conclusion that the MCCA is a public body for purposes of FOIA. | 1 | 2016–2016 |
City of Detroit v. Township of Redford
green
2 sentences2013Pittsfield Charter Twp v Washtenaw Co, 468 Mich 702, 712 ; 664 NW2d 193 (2003); Dave’s Place, Inc v Liquor Control Comm, 277 Mich 551 ; 269 NW 594 (1936); Detroit v Redford Twp, 253 Mich 453, 455-456 ; 235 NW 217 (1931). 35 Rahman, 245 Mich App at 121 . 14 reasons” has no effect on the employer’s obligation to pay weekly benefits under the law.36 C. 2013Pittsfield Charter Twp v Washtenaw Co, 468 Mich 702, 712 ; 664 NW2d 193 (2003); Dave’s Place, Inc v Liquor Control Comm, 277 Mich 551 ; 269 NW 594 (1936); Detroit v Redford Twp, 253 Mich 453, 455-456 ; 235 NW 217 (1931). 35 Rahman, 245 Mich App at 121 . 14 reasons” has no effect on the employer’s obligation to pay weekly benefits under the law.36 C. | 1 | 2013–2013 |
Rahman v. Detroit Board of Education
green
1 sentence2013Pittsfield Charter Twp v Washtenaw Co, 468 Mich 702, 712 ; 664 NW2d 193 (2003); Dave’s Place, Inc v Liquor Control Comm, 277 Mich 551 ; 269 NW 594 (1936); Detroit v Redford Twp, 253 Mich 453, 455-456 ; 235 NW 217 (1931). 35 Rahman, 245 Mich App at 121 . 14 reasons” has no effect on the employer’s obligation to pay weekly benefits under the law.36 C. | 1 | 2013–2013 |
Houghton Lake Area Tourism & Convention Bureau v. Wood
green
2 sentences2010Cf. Houghton Lake Area Tourism & Convention Bureau v Wood, 255 Mich App 127, 151 ; 662 NW2d 758 (2003) (explaining doctrine of expressio unius est exclusio alterius). 2010Cf. Houghton Lake Area Tourism & Convention Bureau v Wood, 255 Mich App 127, 151 ; 662 NW2d 758 (2003) (explaining doctrine of expressio unius est exclusio alterius). | 1 | 2010–2010 |
William Miller v. Allstate Ins Co
green
2 sentences2010Co., 481 Mich. 601, 611 , 751 N.W.2d 463 (2008), is misplaced. 2010In addition, defendant’s reliance on the equally well-established doctrine of expressio unius est exclusio alterius (“the expression of one thing is the exclusion of another”), Miller v Allstate Ins Co, 481 Mich 601, 611 ; 751 NW2d 463 (2008), is misplaced. | 1 | 2010–2010 |
Hoerstman General Contracting, Inc v. Hahn
green
2 sentences2009It has been described as “a rule of construction that is a product of logic and common sense.” Hoerstman Gen Contracting Inc v Hahn, 474 Mich 66, 74 ; 711 NW2d 340 (2006). 2009It has been described as “a rule of construction that is a product of logic and common sense.” Hoerstman Gen Contracting Inc v Hahn, 474 Mich 66, 74 ; 711 NW2d 340 (2006). | 1 | 2009–2009 |
| United States Department of Defense v. Federal Labor Relations Authority green | 1 | 2008–2008 |
United States Department of Justice v. Reporters Committee for Freedom of the Press
green
2 sentences2008It observed that "both the common law and the literal understandings of privacy encompass the individual's control of information concerning his or her person." Id. at 763 , 109 S.Ct. 1468 . [62] See Dep't of Defense, 510 U.S. at 501 , 114 S.Ct. 1006 ("Whatever the reason that these employees have chosen not to . . . provide . . . their addresses, however, it is clear that they have some nontrivial privacy interest in nondisclosure."). [63] Plaintiff relies on the doctrine of expressio unius est exclusio alterius to argue that identifying information can never be exempt under the privacy exemp 2008It observed that "both the common law and the literal understandings of privacy encompass the individual's control of information concerning his or her person." Id. at 763 , 109 S.Ct. 1468 . [62] See Dep't of Defense, 510 U.S. at 501 , 114 S.Ct. 1006 ("Whatever the reason that these employees have chosen not to . . . provide . . . their addresses, however, it is clear that they have some nontrivial privacy interest in nondisclosure."). [63] Plaintiff relies on the doctrine of expressio unius est exclusio alterius to argue that identifying information can never be exempt under the privacy exemp | 1 | 2008–2008 |
FELSNER v. McDONALD RENT-A-CAR, INC
green
2 sentences2008But this Court has held that “[a] fair reading of the language of § 7931(2) does not lead 'one to the conclusion that the rights enumerated therein are all-inclusive.” Felsner v McDonald Rent-A-Car Inc, 173 Mich App 518, 523 ; 434 NW2d 178 (1988). 2008But this Court has held that “[a] fair reading of the language of § 7931(2) does not lead 'one to the conclusion that the rights enumerated therein are all-inclusive.” Felsner v McDonald Rent-A-Car Inc, 173 Mich App 518, 523 ; 434 NW2d 178 (1988). | 1 | 2008–2008 |
| Bradley v. Saranac Community Schools Board of Education green | 1 | 2003–2003 |
| Elliott v. Genesee County neutral | 1 | 2003–2003 |
| McKissic v. Bodine green | 1 | 1999–1999 |
| Selk v. Detroit Plastic Products green | 1 | 1988–1988 |
| Sebewaing Industries, Inc. v. Village of Sebewaing green | 1 | 1984–1984 |
| City of Detroit v. Muzzin & Vincenti, Inc. neutral | 1 | 1981–1981 |
| Bolton v. Cummings green | 1 | 1981–1981 |
| Marshall v. Wabash Railway Co. green | 1 | 1981–1981 |
| Valenti Homes, Inc. v. City of Sterling Heights neutral | 1 | 1978–1978 |
| Huron-Clinton Metropolitan Authority v. Boards of Supervisors green | 1 | 1953–1953 |
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.