Mich. Comp. Laws » Michigan Compiled Laws / Chapter 445 / Act 269 of 1974
Michigan Compiled Laws

Mich. Comp. Laws § 445.1534 (2026)

Civil liability; liability under other statute or common law.

✓ current as of July 2026
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FRANCHISE INVESTMENT LAW


Act 269 of 1974


445.1534 Civil liability; liability under other statute or common law.

Sec. 34.

    Except as explicitly provided in this act, civil liability in favor of any private party shall not arise against a person by implication from or as a result of the violation of a provision of this act or a rule or order hereunder. Nothing in this act shall limit a liability which may exist by virtue of any other statute or under common law if this act were not in effect.

History: 1974, Act 269, Eff. Oct. 15, 1974

Notes of Decisions
Cited in 6 cases (2 in the last 5 years), 1983–2024 · leading case: Toyz, Inc. v. Wireless Toyz, Inc., 799 F. Supp. 2d 737 (E.D. Mich. 2011).
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Toyz, Inc. v. Wireless Toyz, Inc., 799 F. Supp. 2d 737 (E.D. Mich. 2011). · cites it 4× “” MCL § 445.1534 (emphasis added). The plain language of the statute does not limit any other cause of action brought under common law.”
Donald W. Geib, D/B/A Rochester Colonial Amoco v. Amoco Oil Co., a Maryland Corp., 29 F.3d 1050 (6th Cir. 1994). “Mich.Comp.Laws Ann. § 445.1534. The direct conflict between these interpretations of Michigan law within the federal court system, viewed in conjunction with the substantiality of the competing arguments, suggests that this matter can most authoritatively be resolved by the…”
Franchise Mgmt. Unlimited, Inc v. Am.’s Favorite Chicken, 561 N.W.2d 123 (Mich. Ct. App. 1997). “[MCL 445.1534; MSA 19.854(34).] Because the Legislature clearly expressed its intent that the courts not imply a private right of action to remedy violations of the mfil, we may not imply a private cause of action and must find that plaintiffs did not have a claim in the case at…”
Dynamic Enter., Inc. v. Fitness World of Jackson, Inc. (In Re Dynamic Enter., Inc.), 32 B.R. 509 (Bankr. M.D. Tenn. 1983). “Until rescission is effected, the parties continue to operate under the contract.”
Benjamin Franklin Franchising SPE LLC v. David Michael Plumbing, Inc. (E.D. Mich. 2024). · cites it 6× “What’s more, § 445.1534 of the MFIL, by its plain language, appears to foreclose any implied rights of action whatsoever: 1 “Good cause shall include the failure of the franchisee to comply with any lawful provision of the franchise agreement and to cure such failure after being…”
CJ Consultants LLC v. Window World, Inc. (W.D. Mich. 2022). · cites it 5× “Mich. Comp. Laws § 445.1534 . In Franchise Management Unlimited, Inc.”
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