Michigan Compiled Laws
Mich. Comp. Laws § 257.239 (2026)
Certificate of title; failure to endorse or deliver, fine.
✓ current as of July 2026
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MICHIGAN VEHICLE CODE
Act 300 of 1949
257.239 Certificate of title; failure to endorse or deliver, fine.
Sec. 239.
A person shall not fail or neglect to properly endorse and deliver a certificate of title to a transferee or owner lawfully entitled to the title. A person who violates this section is responsible for a civil infraction and shall be ordered to pay a civil fine of not more than $100.00.
History: 1949, Act 300, Eff. Sept. 23, 1949 ;-- Am. 2020, Act 382, Eff. Oct. 1, 2021
Notes of Decisions
Cited in 10
cases, 1952–2017 · leading case: Michigan Mut. Auto Ins. v. Reddig, 341 N.W.2d 847 (Mich. Ct. App. 1983).
Michigan Mut. Auto Ins. v. Reddig, 341 N.W.2d 847 (Mich. Ct. App. 1983). “Consequently, we hold that, at the time of the accident, a sale of a motor vehicle which did not include a transfer of the certificate of title as required by the statute was void. Under such circumstances, the seller remained the owner.”
Whitcraft v. Wolfe, 384 N.W.2d 400 (Mich. Ct. App. 1985). “1935(1); and MCL 257.239; MSA 9.1939. Failure to comply with the statutory requirements relating to endorsement and delivery of the certificate of title renders the transaction void.”
Ladd v. Ford Consum. Fin. Co., Inc., 550 N.W.2d 826 (Mich. Ct. App. 1996). “1935[1], and MCL 257.239; MSA 9.1939). Thus, Whit-craft held that failure to comply with mvc dictates relating to endorsement and delivery of the certificate of title to a motor vehicle rendered the transfer void.”
Gold v. Harper (In re Ambrose-Burbank), 563 B.R. 820 (Bankr. E.D. Mich. 2017). “Section 257.239 provides that “[i]t is a misdemeanor for a person to fail or neglect to properly endorse and deliver a certifícate of title to a transferee or owner lawfully entitled thereto.”
In Re Seal, 192 B.R. 442 (Bankr. W.D. Mich. 1996). “§ 257.239. This is an issue outside of this court’s jurisdiction and may be raised in a court for the State of Michigan.”
Laskowski v. State Farm Mut. Auto. Ins., 429 N.W.2d 887 (Mich. Ct. App. 1988). “This Court noted that Elwart's failure to comply with that statute was a misdemeanor, MCL 257.239; MSA 9.1939. The Court also noted that the purpose of these statutes was to discourage and prevent the stealing of automobiles and to protect the public against crime.”
Bayer v. Jackson City Bank & Trust Co., 55 N.W.2d 746 (Mich. 1952). “” The sections quoted do not in specific terms declare that the failure to execute and deliver a proper certificate of title on the sale of an automobile shall render the transaction void, but section 239 of the code (CL '1948, § 257.239 [Stat Ann 1952 Bev §9.1939]) declares…”
Albanys v. Mid-Century Ins., 282 N.W.2d 11 (Mich. Ct. App. 1979). “Albanys became the owner of the Oldsmobile on January 5, 1977. Title passed when the certificate of title was properly endorsed and delivered to Ms.”
Drettmann v. Marchand, 59 N.W.2d 58 (Mich. 1953). “” By section 239 of the code (CL 1948, § 257.239 [Stat Ann 1952 Rev § 9.1939]) it is declared to he a misdemeanor for any person to fail or neglect to properly indorse and deliver a certificate of title to a transferee to whom, such delivery is required.”
Sroka v. Catsman Transit-Mix Concrete, Inc., 86 N.W.2d 801 (Mich. 1957). “like-» *676 wise void, that the writings in question must be construed together as evidencing a single transaction, and that the trial court was in error in striking the counterclaim: That the agreement for the purchase of the truck was void because of defendants’ failure to…”
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