Mich. Comp. Laws » Michigan Compiled Laws / Chapter 450 / Act 284 of 1972
Michigan Compiled Laws

Mich. Comp. Laws § 450.1851 (2026)

Judicial supervision of corporate affairs and liquidation of assets; permitting creditor to file claim or commence proceeding.

✓ current as of July 2026
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BUSINESS CORPORATION ACT


Act 284 of 1972


450.1851 Judicial supervision of corporate affairs and liquidation of assets; permitting creditor to file claim or commence proceeding.

Sec. 851.

    (1) After a corporation has been dissolved in any manner, the corporation, a creditor, or a shareholder may apply at any time to the circuit court of the county in which the principal place of business or registered office of the corporation is located for a judgment that the affairs of the corporation and the liquidation of its assets continue under supervision of the court. The court shall make orders and judgments as may be required, including, but not limited to, continuance of the liquidation of the corporation's assets by its officers and directors under supervision of the court, or the appointment of a receiver of the corporation to be vested with powers as the court designates to liquidate the affairs of the corporation.

    (2) For good cause shown, and so long as a corporation has not made complete distribution of its assets, the court may permit a creditor who has not delivered his or her claim or commenced a proceeding to enforce his or her claim within the time limits provided in sections 841a and 842a to file the claim or to commence a proceeding within the time as the court directs.

History: 1972, Act 284, Eff. Jan. 1, 1973 ;-- Am. 1973, Act 98, Imd. Eff. Aug. 8, 1973 ;-- Am. 1989, Act 121, Eff. Oct. 1, 1989

Notes of Decisions
Cited in 11 cases (1 in the last 5 years), 1989–2025 · leading case: Baks v. Moroun, 576 N.W.2d 413 (Mich. Ct. App. 1998).
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Baks v. Moroun, 576 N.W.2d 413 (Mich. Ct. App. 1998). · cites it 4× “Moreover, if the majority's view is correct, then the jurisdiction and venue provisions in § 489(1) would merely supplement implicit references to jurisdiction and venue in the act, M.”
Gilliam v. Hi-Temp Prods. Inc., 677 N.W.2d 856 (Mich. Ct. App. 2004). · cites it 3× “MCL 450.1851(2) provides: "For good cause shown, and so long as a corporation has not made complete distribution of its assets, the court may permit a creditor who has not delivered his or her claim or commenced a proceeding to enforce his or her claim within the time limits…”
Scd Chem. Distributors, Inc v. Medley, 512 N.W.2d 86 (Mich. Ct. App. 1994). · cites it 2× “In light of the foregoing, we believe that the property that plaintiff alleges to have been fraudulently conveyed — the inventory, equipment, customers, chemical formulas, product names, and goodwill of Maintenance Research Laboratory, Inc.”
Traverse Bay Area Intermediate Sch. Dist. v. Hitco, Inc., 762 F. Supp. 1298 (W.D. Mich. 1991). · cites it 2× “§ 450.1851(2). The question before the Court is whether the broad liability imposed by CERCLA coupled with the explicit provision that liability attaches “[notwithstanding any other provision or rule of law” permits a plaintiff to maintain a CERCLA lawsuit against a dissolved…”
Estes v. Idea Eng'g & Fabricating, Inc, 649 N.W.2d 84 (Mich. Ct. App. 2002). “Moreover, if the majority’s view is correct, then the jurisdiction and venue provisions in § 489(1) would merely supplement implicit references to jurisdiction and venue in the act, MCL 450.”
City of South Bend v. Century Indem. Co., 821 N.E.2d 5 (Ind. Ct. App. 2005). “Mich. Comp. Laws § 450.1851 . 7 . Specifically, the City alleged that the predecessor to Century was Studebaker's primary general liability insurer from at least October 13, 1949 through November 20, 1957; Zurich was Studebaker's primary general liability insurer from December…”
Gilliam v. Hi-Temp Prods., Inc., 677 N.W.2d 856 (Mich. Ct. App. 2003). · cites it 3× “MCL 450.1851(2) provides: “For good cause shown, and so long as a corporation has not made complete distribution of its assets, the court may permit a creditor who has not delivered his or her claim or commenced a proceeding to enforce his or her claim within the time limits…”
Christner v. Anderson, Nietzke & Co., Pc, 444 N.W.2d 779 (Mich. 1989). “[MCL 450.1851(1); MSA 21.200(851X1).] Section 3605 of the Revised Judicature Act also provides, in part: (1) Circuit courts have the power, and actions may be brought in the circuit courts: (a) to compel persons to account for their conduct in the management and disposition of…”
BASF Corp. v. Cent. Transp., Inc., 830 F. Supp. 1011 (E.D. Mich. 1993). “A § 450.1851(2). Because Hughes Chemical was dissolved in 1982, defendant argues that it is no longer subject to suit.”
Darshan Singh Grewal v. Gurmale Singh Grewal (Mich. Ct. App. 2019). “Plaintiffs requested an accounting, judicial supervision of dissolution distributions pursuant to MCL 450.1851 and -7- 450.4805, and also alleged that defendants engaged in fraudulent transfers in violation of the Uniform Fraudulent Transfer Act, MCL 566.”
HPIL Holding, Inc. v. Haining Zhang (E.D. Mich. 2025). “LAWS § 450.1851(1). And the statute allows the court to “make orders and judgments as may be required” to rehabilitate the company, “including, but not limited to, .”
— Mich. Comp. Laws § 450.1851(1) — 3 cases
Scd Chem. Distributors, Inc v. Medley, 512 N.W.2d 86 (Mich. Ct. App. 1994). “In light of the foregoing, we believe that the property that plaintiff alleges to have been fraudulently conveyed — the inventory, equipment, customers, chemical formulas, product names, and goodwill of Maintenance Research Laboratory, Inc.”
Christner v. Anderson, Nietzke & Co., Pc, 444 N.W.2d 779 (Mich. 1989). “[MCL 450.1851(1); MSA 21.200(851X1).] Section 3605 of the Revised Judicature Act also provides, in part: (1) Circuit courts have the power, and actions may be brought in the circuit courts: (a) to compel persons to account for their conduct in the management and disposition of…”
HPIL Holding, Inc. v. Haining Zhang (E.D. Mich. 2025). “LAWS § 450.1851(1). And the statute allows the court to “make orders and judgments as may be required” to rehabilitate the company, “including, but not limited to, .”
— Mich. Comp. Laws § 450.1851(2) — 4 cases
Gilliam v. Hi-Temp Prods. Inc., 677 N.W.2d 856 (Mich. Ct. App. 2004). “MCL 450.1851(2) provides: "For good cause shown, and so long as a corporation has not made complete distribution of its assets, the court may permit a creditor who has not delivered his or her claim or commenced a proceeding to enforce his or her claim within the time limits…”
Traverse Bay Area Intermediate Sch. Dist. v. Hitco, Inc., 762 F. Supp. 1298 (W.D. Mich. 1991). “§ 450.1851(2). The question before the Court is whether the broad liability imposed by CERCLA coupled with the explicit provision that liability attaches “[notwithstanding any other provision or rule of law” permits a plaintiff to maintain a CERCLA lawsuit against a dissolved…”
Gilliam v. Hi-Temp Prods., Inc., 677 N.W.2d 856 (Mich. Ct. App. 2003). “MCL 450.1851(2) provides: “For good cause shown, and so long as a corporation has not made complete distribution of its assets, the court may permit a creditor who has not delivered his or her claim or commenced a proceeding to enforce his or her claim within the time limits…”
BASF Corp. v. Cent. Transp., Inc., 830 F. Supp. 1011 (E.D. Mich. 1993). “A § 450.1851(2). Because Hughes Chemical was dissolved in 1982, defendant argues that it is no longer subject to suit.”
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