Michigan Compiled Laws
Mich. Comp. Laws § 37.2801 (2026)
Action for injunctive relief or damages; venue; “damages” defined.
✓ current as of July 2026
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ELLIOTT-LARSEN CIVIL RIGHTS ACT
Act 453 of 1976
37.2801 Action for injunctive relief or damages; venue; “damages” defined.
Sec. 801.
(1) A person alleging a violation of this act may bring a civil action for appropriate injunctive relief or damages, or both.
(2) An action commenced pursuant to subsection (1) may be brought in the circuit court for the county where the alleged violation occurred, or for the county where the person against whom the civil complaint is filed resides or has his principal place of business.
(3) As used in subsection (1), "damages" means damages for injury or loss caused by each violation of this act, including reasonable attorney's fees.
History: 1976, Act 453, Eff. Mar. 31, 1977
Notes of Decisions
Cited in 101
cases (12 in the last 5 years), 1978–2025 · leading case: Rasheed v. Chrysler Corp., 517 N.W.2d 19 (Mich. 1994).
Rasheed v. Chrysler Corp., 517 N.W.2d 19 (Mich. 1994). “] The remedies listed under article 8 of the Michigan Civil Rights Act, MCL 37.2801 et seq.; MSA 3.548(801) et seq.”
Major v. Vill. of Newberry, 892 N.W.2d 402 (Mich. Ct. App. 2016). “MCL 37.2801(1) and (2). The CRA “shall not be construed to diminish the right of a person to direct or immediate legal or equitable remedies in the courts of the state.”
Elezovic v. Ford Motor Co., 697 N.W.2d 851 (Mich. 2005). “" Mich. Comp. Laws §§ 37.2801 (1), (3). These ELCRA remedies further distinguish it from Title VII because damages can be obtained from individuals as well as employers.”
Eide v. Kelsey-Hayes Co., 427 N.W.2d 488 (Mich. 1988). “[MCL 37.2801; MSA 3.548(801).] Clearly, there is no express provision in the Civil Rights Act for exemplary damages.”
Nummer v. Dep't of Treasury, 533 N.W.2d 250 (Mich. 1995). “Where such a proceeding is pending, the commission or department may, in its discretion, delay consideration or action on the complaint filed. [1979 AC, R 37.4(4)(e).”
Matras v. Amoco Oil Co., 385 N.W.2d 586 (Mich. 1986). “[26] MCL 37.2801; MSA 3.548(801). [27] The cause, however, was submitted to the jury only on the FEPA count because the substantive right arose out of an act of discrimination that occurred before the effective date of the Civil Rights Act.”
Brandon Brightwell v. Fifth Third Bank of Michigan, 790 N.W.2d 591 (Mich. 2010). “4 We disagree with the Barnes decision and overrule it.”
Gilbert v. DaimlerChrysler Corp., 685 N.W.2d 391 (Mich. 2004). “[21] MCL 37.2801(3). [22] There is also an overarching constitutional issue to consider.”
MacK v. City of Detroit, 649 N.W.2d 47 (Mich. 2002). “[MCL 37.2801(1) (emphasis added).] [11] In sum, without some express legislative authorization, the city cannot create a cause of action against itself in contravention of the broad scope of governmental immunity established by the GTLA.”
Kassab v. Michigan Basic Prop. Ins., 491 N.W.2d 545 (Mich. 1992). “MCL 37.2801 and 37.2802; MSA 3.548(801) and 3.”
Holmes v. Haughton Elevator Co., 272 N.W.2d 550 (Mich. 1978). “MCL 37.2801; MSA 3.548(801). Not only was direct access granted for claims of race discrimination, but also for age, sex, national origin, religion, handicap and marital status claims.”
Betts v. Costco Wholesale Corp., 558 F.3d 461 (6th Cir. 2009). “Mich. Comp. Laws § 37.2801 . Claims for damages under the ELCRA may thus include a loss of wages.”
— Mich. Comp. Laws § 37.2801(1) — 32 cases
Rasheed v. Chrysler Corp., 517 N.W.2d 19 (Mich. 1994). “] The remedies listed under article 8 of the Michigan Civil Rights Act, MCL 37.2801 et seq.; MSA 3.548(801) et seq.”
Major v. Vill. of Newberry, 892 N.W.2d 402 (Mich. Ct. App. 2016). “MCL 37.2801(1) and (2). The CRA “shall not be construed to diminish the right of a person to direct or immediate legal or equitable remedies in the courts of the state.”
Eide v. Kelsey-Hayes Co., 427 N.W.2d 488 (Mich. 1988). “[MCL 37.2801; MSA 3.548(801).] Clearly, there is no express provision in the Civil Rights Act for exemplary damages.”
MacK v. City of Detroit, 649 N.W.2d 47 (Mich. 2002). “[MCL 37.2801(1) (emphasis added).] [11] In sum, without some express legislative authorization, the city cannot create a cause of action against itself in contravention of the broad scope of governmental immunity established by the GTLA.”
McClements v. Ford Motor Co., 702 N.W.2d 166 (Mich. 2005).
— Mich. Comp. Laws § 37.2801(2) — 13 cases
Brandon Brightwell v. Fifth Third Bank of Michigan, 790 N.W.2d 591 (Mich. 2010). “4 We disagree with the Barnes decision and overrule it.”
Deborah Reynolds v. Robert Hasbany Md Pllc, 917 N.W.2d 715 (Mich. Ct. App. 2018).
Jane Doe v. Dep't of Transp., 919 N.W.2d 670 (Mich. Ct. App. 2018).
Barnes v. Int'l Bus. MacHines Corp., 537 N.W.2d 265 (Mich. Ct. App. 1995).
Brightwell v. Fifth Third Bank of Michigan, 772 N.W.2d 427 (Mich. 2009).
— Mich. Comp. Laws § 37.2801(3) — 8 cases
Gilbert v. DaimlerChrysler Corp., 685 N.W.2d 391 (Mich. 2004). “[21] MCL 37.2801(3). [22] There is also an overarching constitutional issue to consider.”
Rasheed v. Chrysler Corp., 517 N.W.2d 19 (Mich. 1994). “] The remedies listed under article 8 of the Michigan Civil Rights Act, MCL 37.2801 et seq.; MSA 3.548(801) et seq.”
Ledsinger v. Burmeister, 318 N.W.2d 558 (Mich. Ct. App. 1982).
Schellenberg v. Rochester, Michigan, Lodge No 2225 of the Benevolent & Prot. Order of Elks of the United States of Am., 577 N.W.2d 163 (Mich. Ct. App. 1998).
Seals v. Henry Ford Hosp., 333 N.W.2d 272 (Mich. Ct. App. 1983).
— Mich. Comp. Laws § 37.2801(a) — 2 cases
Varlesi v. Wayne State Univ., 909 F. Supp. 2d 827 (E.D. Mich. 2012).
Richard Miller v. Michigan Dep't of Corr. (Mich. Ct. App. 2022).
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