Mich. Comp. Laws » Michigan Compiled Laws / Chapter 15 / Act 469 of 1980
Michigan Compiled Laws

Mich. Comp. Laws § 15.364 (2026)

Court judgment; order; remedies; awarding costs of litigation.

✓ current as of July 2026
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THE WHISTLEBLOWERS' PROTECTION ACT


Act 469 of 1980


15.364 Court judgment; order; remedies; awarding costs of litigation.

Sec. 4.

    A court, in rendering a judgment in an action brought pursuant to this act, shall order, as the court considers appropriate, reinstatement of the employee, the payment of back wages, full reinstatement of fringe benefits and seniority rights, actual damages, or any combination of these remedies. A court may also award the complainant all or a portion of the costs of litigation, including reasonable attorney fees and witness fees, if the court determines that the award is appropriate.

History: 1980, Act 469, Eff. Mar. 31, 1981

Notes of Decisions
Cited in 24 cases (3 in the last 5 years), 1984–2022 · leading case: Theodore Cadwell v. City of Highland Park, 922 N.W.2d 639 (Mich. Ct. App. 2018).
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Theodore Cadwell v. City of Highland Park, 922 N.W.2d 639 (Mich. Ct. App. 2018). · cites it 9× “, may recover postjudgment attorney fees under MCL 15.364. However, because the trial court failed to properly evaluate whether the requested attorney fees were reasonable and appropriate, we vacate the court's order awarding postjudgment attorney fees and remand for further…”
O’neill v. Home IV Care, Inc, 643 N.W.2d 600 (Mich. Ct. App. 2002). · cites it 16× “Plaintiff Mary O’Neill appeals as of right from an order awarding her attorney fees, costs, and interest pursuant to MCL 15.364, § 4 of the Whistle-blowers’ Protection Act (wpa), MCL 15.”
Anzaldua v. Band, 578 N.W.2d 306 (Mich. 1998). · cites it 6× “] Section 4 delineates the potential remedies that are available to a successful claimant: A court, in rendering a judgment in an action brought pursuant to this act, shall order, as the court considers appropriate, reinstatement of the employee, the payment of back wages, full…”
Lease Acceptance Corp. v. Adams, 724 N.W.2d 724 (Mich. Ct. App. 2006). · cites it 2× “2d 532 (1997) (recognizing that the trial court may award reasonable attorney fees pursuant to the Whistleblowers' Protection Act, MCL 15.364, and that the decision is reviewed for an abuse of discretion).”
Bailets, R. v. Pa. Tpk. Comm'n, Aplt., 181 A.3d 324 (Pa. 2018). “Additionally, the Michigan Whistleblowers' Protection Act, which is practically identical to Pennsylvania's Law, provides for the remedy of "actual damages," and Michigan jurisprudence has noted damages for emotional distress and humiliation are clearly authorized thereby.”
Covell v. Spengler, 366 N.W.2d 76 (Mich. Ct. App. 1985). · cites it 3× “Plaintiff also contends that if the statute is to be construed as a statute of limitations it only bars the two forms of relief specified in that provision, injunctive relief and actual damages, and does not bar an action for the other remedies enumerated in MCL 15.364; MSA…”
Madugula v. Taub, 853 N.W.2d 75 (Mich. 2014). “27 MCL 15.364. 28 Anzaldua, 457 Mich at 536 .”
Anzaldua v. Band, 550 N.W.2d 544 (Mich. Ct. App. 1996). · cites it 3× “Accordingly, we must decide between the two approaches to resolve the issue before us. Mindful that our ultimate task is to interpret this constitutional provision, we conclude that the better test of whether the constitutional right to a jury trial is retained is the…”
Phinney v. Perlmutter, 564 N.W.2d 532 (Mich. Ct. App. 1997). “” MCL 15.364; MSA 17.428(4). If the language of a statute is clear and unambiguous, the plain meaning of the statute reflects the legislative intent and judicial construction *561 is not permitted.”
DeOrnellas v. Aspen Square Mgmt., Inc., 295 F. Supp. 2d 753 (E.D. Mich. 2003). · cites it 2× “Mich. Comp. Laws § 15.364 . The defendant argues that a close analysis of the two states’ laws reveals little difference between the two since Michigan’s WPA does not automatically entitle the plaintiffs to attorney’s fees and Massachusetts common law allows for an award of…”
Melchi v. Burns Int'l Sec. Servs., Inc., 597 F. Supp. 575 (E.D. Mich. 1984). “§ 15.364 21. ) Plaintiff has requested reinstatement, back pay including vacation benefits, and damages for emotional distress and humiliation.”
Natalie Reeser v. Henry Ford Hosp., 695 F. App'x 876 (6th Cir. 2017). · cites it 2× “” Mich. Comp. Laws § 15.364 . Reeser requested $315,133.”
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