Michigan Compiled Laws

Mich. Comp. Laws § 445.772 (2026)

Unlawful contract, combination, or conspiracy.

✓ current as of July 2026
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MICHIGAN ANTITRUST REFORM ACT


Act 274 of 1984


445.772 Unlawful contract, combination, or conspiracy.

Sec. 2.

    A contract, combination, or conspiracy between 2 or more persons in restraint of, or to monopolize, trade or commerce in a relevant market is unlawful.

History: 1984, Act 274, Eff. Mar. 29, 1985

Notes of Decisions
Cited in 45 cases (5 in the last 5 years), 1985–2026 · leading case: Innovation Ventures v. Liquid Mfg., 885 N.W.2d 861 (Mich. 2016).
Innovation Ventures v. Liquid Mfg., 885 N.W.2d 861 (Mich. 2016). · cites it 3× “13 MCL 445.772, which governs general agreements, provides that “[a] contract, combination, or conspiracy between 2 or more persons in restraint of, or to monopolize, trade or commerce in a relevant market is unlawful.”
In re Cardizem CD Antitrust Litig., 200 F.R.D. 326 (E.D. Mich. 2001). · cites it 3× “Thus, the focus here will be on indirect purchasers in Michigan who are seeking: (1) equitable relief in the nature of disgorgement of Defendants’ unjust enrichment; (2) treble damages, jointly and severally, for Defendants’ violations of §§ 445.772 1 and 445.773 2 of the…”
BPS Clinical Labs. v. Blue Cross & Blue Shield, 552 N.W.2d 919 (Mich. Ct. App. 1996). · cites it 3× “*693 MCL 445.772; MSA 28.70(2). Defendant maintained that plaintiffs’ claims were preempted by the erisa.”
Certified Restoration Dry Cleaning Network, L.L.C. v. Tenke Corp., 511 F.3d 535 (6th Cir. 2007). “Reasonableness of the Non-Compete Covenant In addition to erroneously finding the non-compete clause ambiguous, the district court improperly concluded that there was insufficient evidence to de *546 termine whether Plaintiff would likely succeed in convincing the court that the…”
Rooyakker & Sitz, PLLC v. Plante & Moran, PLLC, 742 N.W.2d 409 (Mich. Ct. App. 2007). · cites it 2× “VIOLATIONS OF THE MARA Plaintiffs allege that the agreement’s client solicitation clause is a noncompetition agreement that violates § 2 of the MARA, MCL 445.772, and, therefore, is unenforceable.”
In Re Packaged Ice Antitrust Litig., 779 F. Supp. 2d 642 (E.D. Mich. 2011). · cites it 2× “Michigan The IP Plaintiffs allege that Defendants have violated the Michigan Antitrust Reform Act, Mich. Comp. Laws Ann. § 445.772 ("MARA").”
Blair v. Checker Cab Co., 558 N.W.2d 439 (Mich. Ct. App. 1997). · cites it 3× “Plaintiff then filed a lawsuit against defendant, alleging: (1) the hearing she was provided was contrary to defendant’s constitution and bylaws and denied her due process; (2) the antitampering bylaw implemented an unconstitutional system of involuntary servitude; and (3) the…”
Bristol Window & Door, Inc. v. Hoogenstyn, 650 N.W.2d 670 (Mich. Ct. App. 2002). · cites it 2× “772, which was derived from the Uniform State Antitrust Act, sets forth the following general proposition: “A contract, combination, or conspiracy between 2 or more persons in restraint of, or to monopolize, trade or commerce in a relevant market is unlawful.”
United States v. Microsoft Corp., 87 F. Supp. 2d 30 (D.D.C. 2000). · cites it 2× “93A, § 2; Mich. Comp. Laws §§ 445.772 , 445.773; MinmStat.”
St Clair Med., PC v. Borgiel, 715 N.W.2d 914 (Mich. Ct. App. 2006). “” MCL 445.772. But, agreements not to compete are authorized by § 4a(l) of the MARA, MCL 445.”
In Re Potash Antitrust Litig., 667 F. Supp. 2d 907 (N.D. Ill. 2009). “See Mich. Comp. Laws Ann. § 445.772 (“A contract, combination, or conspiracy between 2 or more persons in restraint of, or to monopolize, trade or commerce in a relevant market is unlawful.”
Little Caesar Enter., Inc. v. Smith, 895 F. Supp. 884 (E.D. Mich. 1995). · cites it 4× “Count III is an identical claim under MCLA § 445.772 of Michigan’s antitrust statute.”
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