Mich. Comp. Laws » Michigan Compiled Laws / Chapter 37 / Act 220 of 1976
Michigan Compiled Laws

Mich. Comp. Laws § 37.1102 (2026)

Opportunity guaranteed; civil right; accommodation of person with disability; undue hardship.

✓ current as of July 2026
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PERSONS WITH DISABILITIES CIVIL RIGHTS ACT


Act 220 of 1976


37.1102 Opportunity guaranteed; civil right; accommodation of person with disability; undue hardship.

Sec. 102.

    (1) The opportunity to obtain employment, housing, and other real estate and full and equal utilization of public accommodations, public services, and educational facilities without discrimination because of a disability is guaranteed by this act and is a civil right.

    (2) Except as otherwise provided in article 2, a person shall accommodate a person with a disability for purposes of employment, public accommodation, public service, education, or housing unless the person demonstrates that the accommodation would impose an undue hardship.

History: 1976, Act 220, Eff. Mar. 31, 1977 ;-- Am. 1980, Act 478, Imd. Eff. Jan. 20, 1981 ;-- Am. 1990, Act 121, Imd. Eff. June 25, 1990 ;-- Am. 1998, Act 20, Imd. Eff. Mar. 12, 1998

Notes of Decisions
Cited in 93 cases (19 in the last 5 years), 1982–2026 · leading case: Bachman v. Swan Harbour Assocs., 653 N.W.2d 415 (Mich. Ct. App. 2002).
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Bachman v. Swan Harbour Assocs., 653 N.W.2d 415 (Mich. Ct. App. 2002). · cites it 9× “In the instant case, plaintiff argues that defendants violated certain provisions of articles 1, 5, and 6 of the pwdcra as follows: (1) defendants refused to accommodate his disability, MCL 37.1102 and MCL 37.1506a, (2) defendants actively discriminated against him on the basis…”
Joseph Casias v. Wal-Mart Stores, Inc., 695 F.3d 428 (6th Cir. 2012). · cites it 2× “”); Persons With Disabilities Civil Rights Act of 1976, Mich. Comp. Laws § 37.1102 (1) (“[A]n employer shall not .”
Rourk v. Oakwood Hosp. Corp., 580 N.W.2d 397 (Mich. 1998). · cites it 8× “§ 37.1102(1); M.S.A. § 3.550(102)(1). A person is handicapped under the HCRA whose physical or mental condition substantially limits one or more major life activity and is unrelated to the person's ability to perform a particular job or position with or without accommodation.”
James P. Smith v. Chrysler Corp., 155 F.3d 799 (6th Cir. 1998). · cites it 2× “” Mich. Comp. Laws Ann. § 37.1102 (a) (West 1997).”
Peden v. City of Detroit, 680 N.W.2d 857 (Mich. 2004). · cites it 2× “MCL 37.1102(1). In order to avoid transforming the PWDCRA from an antidiscrimination statute into something that is unwarrantedly broader, we believe that the judgment of the employer regarding the duties of a given job position is entitled to substantial deference.”
303 Creative LLC v. Elenis, 600 U.S. 570 (2023). “272, § 98 (2020); Mich. Comp. Laws §§ 37.1102 , 37.2302 (1981), as amended, 2023 Mich.”
Wardlow v. Great Lakes Express Co., 339 N.W.2d 670 (Mich. Ct. App. 1983). · cites it 4× “Of course, in that situation, no accommodation is needed in the first place. In other words, defendant's interpretation requires accommodation only when no accommodation is needed.”
Roger Monette & Doris Monette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996). “§ 12101 , and the Michigan Handicappers’ Civil Rights Act, Mich. Comp. Laws § 37.1102 . 1 The defendant subsequently removed the case to federal court in the Eastern District of Michigan.”
Carr v. Gen. Motors Corp., 389 N.W.2d 686 (Mich. 1986). · cites it 2× “MCL 37.1102; MSA 3.550(102) requires accommodation.”
Hall v. Hackley Hosp., 532 N.W.2d 893 (Mich. Ct. App. 1995). · cites it 4× “, alleging that defendant failed to accommodate her asthma as required by MCL 37.1102(2); MSA 3.550(102)(2). Defendant moved for summary disposition pursuant to MCR 2.”
Loretta Steward v. New Chrysler, 415 F. App'x 632 (6th Cir. 2011). · cites it 2× “Michigan’s PWDCRA, Mich. Comp. Laws § 37.1102 (1)–(2), “substantially mirrors” the ADA, and claims under both statutes are generally analyzed identically, Cotter v.”
Rose v. Wayne Cnty. Airport Auth., 210 F. Supp. 3d 870 (E.D. Mich. 2016). · cites it 2× “The same can be said for claims under Michigan’s Persons With Disabilities Civil Rights Act, Mich. Comp. Laws § 37.1102 (1), which “substantially mirrors the ADA.”
Show all 93 citing cases →
— Mich. Comp. Laws § 37.1102(1) — 21 cases
Peden v. City of Detroit, 680 N.W.2d 857 (Mich. 2004). “MCL 37.1102(1). In order to avoid transforming the PWDCRA from an antidiscrimination statute into something that is unwarrantedly broader, we believe that the judgment of the employer regarding the duties of a given job position is entitled to substantial deference.”
Bachman v. Swan Harbour Assocs., 653 N.W.2d 415 (Mich. Ct. App. 2002). “In the instant case, plaintiff argues that defendants violated certain provisions of articles 1, 5, and 6 of the pwdcra as follows: (1) defendants refused to accommodate his disability, MCL 37.1102 and MCL 37.1506a, (2) defendants actively discriminated against him on the basis…”
Rourk v. Oakwood Hosp. Corp., 580 N.W.2d 397 (Mich. 1998). “§ 37.1102(1); M.S.A. § 3.550(102)(1). A person is handicapped under the HCRA whose physical or mental condition substantially limits one or more major life activity and is unrelated to the person's ability to perform a particular job or position with or without accommodation.”
Casias v. Wal-Mart Stores, Inc., 764 F. Supp. 2d 914 (W.D. Mich. 2011).
Mahaffey Ex Rel. Mahaffey v. Aldrich, 236 F. Supp. 2d 779 (E.D. Mich. 2002).
— Mich. Comp. Laws § 37.1102(18) — 1 case
Holly v. Beaumont Health (E.D. Mich. 2023).
— Mich. Comp. Laws § 37.1102(2) — 39 cases
Bachman v. Swan Harbour Assocs., 653 N.W.2d 415 (Mich. Ct. App. 2002). “In the instant case, plaintiff argues that defendants violated certain provisions of articles 1, 5, and 6 of the pwdcra as follows: (1) defendants refused to accommodate his disability, MCL 37.1102 and MCL 37.1506a, (2) defendants actively discriminated against him on the basis…”
Rourk v. Oakwood Hosp. Corp., 580 N.W.2d 397 (Mich. 1998). “§ 37.1102(1); M.S.A. § 3.550(102)(1). A person is handicapped under the HCRA whose physical or mental condition substantially limits one or more major life activity and is unrelated to the person's ability to perform a particular job or position with or without accommodation.”
Hall v. Hackley Hosp., 532 N.W.2d 893 (Mich. Ct. App. 1995). “, alleging that defendant failed to accommodate her asthma as required by MCL 37.1102(2); MSA 3.550(102)(2). Defendant moved for summary disposition pursuant to MCR 2.”
Moses, Inc v. Se. Michigan Council of Governments, 716 N.W.2d 278 (Mich. Ct. App. 2006).
Wardlow v. Great Lakes Express Co., 339 N.W.2d 670 (Mich. Ct. App. 1983). “Of course, in that situation, no accommodation is needed in the first place. In other words, defendant's interpretation requires accommodation only when no accommodation is needed.”
— Mich. Comp. Laws § 37.1102(l) — 1 case
Chandler v. Dowell Schlumberger, Inc, 542 N.W.2d 310 (Mich. Ct. App. 1995).
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