Michigan Compiled Laws

Mich. Comp. Laws § 565.961 (2026)

Other obligations created by law not limited.

✓ current as of July 2026

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SELLER DISCLOSURE ACT

Act 92 of 1993

565.961 Other obligations created by law not limited.

Sec. 11.

The specification of items for disclosure in this act does not limit or abridge any obligation for disclosure created by any other provision of law regarding fraud, misrepresentation, or deceit in transfer transactions.

History: 1993, Act 92, Eff. Jan. 10, 1994

Notes of Decisions

Cited in 5 cases (2 in the last 5 years), 2005–2025 · leading case: Roberts v. Saffell, 760 N.W.2d 715 (Mich. Ct. App. 2008).

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Roberts v. Saffell, 760 N.W.2d 715 (Mich. Ct. App. 2008). · cites it 4× “" MCL 565.961. That is, apart from the SDS, the Legislature has not modified the rule of caveat emptor and its common-law exceptions imposing liability for fraud.”

Bergen v. Baker, 691 N.W.2d 770 (Mich. Ct. App. 2005). ““The specification of items for disclosure in this act does not limit or abridge any obligation for disclosure created by any other provision of law regarding fraud, misrepresentation, or deceit in transfer transactions.”

Paul Locher v. Est. of Bradley M Zimmerman (Mich. Ct. App. 2020). “” MCL 565.961. We therefore conclude that the SDA does not create an independent cause of action but instead relies on common-law causes of action in fraud to operate as the SDA-enforcement mechanisms.”

Sammar T Faraj v. Ronald Giles (Mich. Ct. App. 2024). “” MCL 565.961. In short, it is evident that the Legislature intended to allow for seller liability in a civil action alleging fraud or violation of the act brought by a purchaser on the basis of -5- misrepresentations or omissions in a disclosure statement, but with some…”

Leandre Gholston v. Scott Sherrill (Mich. Ct. App. 2025). “” MCL 565.961. In line with this, plaintiffs sought rescission of the transaction under theories of fraudulent misrepresentation and silent fraud against defendants, both of which involve a seller’s knowing misrepresentation about a material fact.”

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