Mich. Comp. Laws » Michigan Compiled Laws / Chapter 37 / Act 453 of 1976
Michigan Compiled Laws

Mich. Comp. Laws § 37.2401 (2026)

Definition.

✓ current as of July 2026
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ELLIOTT-LARSEN CIVIL RIGHTS ACT


Act 453 of 1976


37.2401 Definition.

Sec. 401.

    As used in this article, "educational institution" means a public or private institution, or a separate school or department thereof, and includes an academy, college, elementary or secondary school, extension course, kindergarten, nursery, local school system, university, or a business, nursing, professional, secretarial, technical, or vocational school; and includes an agent of an educational institution.

History: 1976, Act 453, Eff. Mar. 31, 1977

Notes of Decisions
Cited in 14 cases (6 in the last 5 years), 1988–2025 · leading case: Eide v. Kelsey-Hayes Co., 427 N.W.2d 488 (Mich. 1988).
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Eide v. Kelsey-Hayes Co., 427 N.W.2d 488 (Mich. 1988). · cites it 2× “, education, MCL 37.2401 et seq.; MSA 3.548(401) et seq.”
Communities for Equity v. Michigan High Sch. Athletic Ass'n, 178 F. Supp. 2d 805 (W.D. Mich. 2001). · cites it 2× “Mich. Comp. Laws § 37.2402 (2001). The definition of “educational institutions” includes “an agent of an educational institution.”
Varlesi v. Wayne State Univ., 909 F. Supp. 2d 827 (E.D. Mich. 2012). · cites it 4× “See Mich. Comp. Laws § 37.2401 . Thus, if a reasonable jury could find that SA was acting as an agent of WSU, Plaintiffs EL-CRA claim against SA must proceed.”
Bettina Winkler v. Marist Fathers of Detroit Inc, 909 N.W.2d 311 (Mich. Ct. App. 2017). · cites it 2× “First addressing the CRA, MCL 37.2401 provides a definition of the term "educational institution" to that is almost identical to the definition set forth in the PWDCRA.”
Regents of Univ. v. State, 419 N.W.2d 773 (Mich. Ct. App. 1988). · cites it 2× “MCL 37.2401 et seq.; MSA 3.548(401) et seq.”
Communities for Equity v. Michigan High Sch. Athletic Ass'n, 26 F. Supp. 2d 1001 (W.D. Mich. 1998). “2402, Defendants contend MHSAA and individual Defendants are not “educational institutions” subject to the statute’s strictures.”
Jane Doe v. Alpena Pub. Sch. Dist. (Mich. 2024). · cites it 5× “MCL 37.2401 defines “educational institution” to include, among other things, “an agent of an educational institution.”
One v. MacOmb Intermediate Sch. Dist. (Mich. Ct. App. 2023). · cites it 2× “Article 4 of the ELCRA addresses the issue of discrimination by educational institutions, MCL 37.2401 et seq. MCL 37.2801 permits a civil cause of action against educational institutions for violation of the act.”
Beny v. Univ. of Michigan (E.D. Mich. 2023). · cites it 2× “” Mich. Comp. Laws § 37.2401 . The “agent” language mirrors Title VII, which, as noted above, has been interpreted by the court of appeals to preclude individual liability.”
K.S. v. Detroit Pub. Schs., 130 F. Supp. 3d 1073 (E.D. Mich. 2015). · cites it 2× “” Mich. Comp. Laws § 37.2401 . The Act further specifies that “[djisqrimination because of sex includes sexual harassment.”
Jane Doe v. Marshall Pub. Schs. (Mich. Ct. App. 2023). “Article 4 of the ELCRA, MCL 37.2401 et seq., specifically targets discrimination within educational institutions, including public high schools.”
Doe v. Univ. of Michigan (E.D. Mich. 2020). “LAWS § 37.2401 (“As used in this article, ‘educational institution’… includes an agent of an educational institution.”
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