Mich. Comp. Laws » Michigan Compiled Laws / Chapter 600 / Act 236 of 1961
Michigan Compiled Laws

Mich. Comp. Laws § 600.1645 (2026)

Improper venue; judgment.

✓ current as of July 2026
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REVISED JUDICATURE ACT OF 1961


Act 236 of 1961


600.1645 Improper venue; judgment.

Sec. 1645.

    No order, judgment, or decree shall be void or voidable solely on the ground that there was improper venue.

History: 1961, Act 236, Eff. Jan. 1, 1963

Notes of Decisions
Cited in 20 cases (3 in the last 5 years), 1968–2026 · leading case: People v. Houthoofd, 487 Mich. 568 (Mich. 2010).
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People v. Houthoofd, 487 Mich. 568 (Mich. 2010). · cites it 98× “Moreover, MCL 600.1645 explicitly provides that no judgment shall be voided solely on the basis of improper venue.”
Kohn v. Ford Motor Co., 390 N.W.2d 709 (Mich. Ct. App. 1986). · cites it 4× “Plaintiff's failure to apply for leave to appeal, although it may not technically violate MCL 600.1645; MSA 27A.1645, which deals with the failure of a party to move for a change of venue prior to judgment, certainly violates the spirit of that statute, which provides: No order,…”
City of Riverview v. Sibley Limestone, 716 N.W.2d 615 (Mich. Ct. App. 2006). “Nevertheless, MCL 600.1645 provides that “[n]o order, judgment, or decree shall be void or voidable solely on the ground that there was improper venue.”
Gross v. Gen. Motors Corp., 502 N.W.2d 365 (Mich. Ct. App. 1993). · cites it 4× “To require plaintiff to raise the issue following a trial in the Washtenaw Circuit Court would effectively deny plaintiff the opportunity to have a resolution on the merits of whether the original change of venue was proper.”
People v. Aspy, 808 N.W.2d 569 (Mich. Ct. App. 2011). “26, and that MCL 600.1645 explicitly provides that no judgment shall be voided solely on the basis of improper venue).”
In re Forfeiture of a Quantity of Marijuana, 805 N.W.2d 217 (Mich. Ct. App. 2011). “See MCL 600.1645 (“No order, judgment, or decree shall be void or voidable solely on the ground that there was improper venue.”
Bass v. Combs, 604 N.W.2d 727 (Mich. Ct. App. 2000). “” MCL 600.1645; MSA 27A.1645. Therefore, the Oakland Circuit Court’s ultimate order dismissing plaintiff’s case cannot be set aside merely on the basis that the Wayne Circuit Court improperly trans *23 ferred venue, and we must proceed to address plaintiff’s further allegations…”
Triplett v. St Amour, 507 N.W.2d 194 (Mich. 1993). · cites it 2× “[8] Because the trial court had the power to grant summary disposition regardless of the venue, MCL 600.1645; MSA 27A.1645, the venue issue is moot because the trial court's action precluded the requested change.”
Stamadianos v. Stamadianos, 350 N.W.2d 268 (Mich. Ct. App. 1984). · cites it 2× “MCL 600.1645; MSA 27A.1645; GCR 1963, 401, 402, 409.”
Grebner v. Clinton Charter Twp., 550 N.W.2d 265 (Mich. Ct. App. 1996). “” MCL 600.1645; MSA 27A.1645. The proper manner in which to raise this issue is an interlocutory appeal from the order denying the motion for a change of venue.”
Whiting v. Neuman, 160 N.W.2d 795 (Mich. Ct. App. 1968). “” CLS *207 1961, § 600.1645 (Stat Ann 1962 Eev § 27A.1645).”
People of Michigan v. Jeremiah James Boshell (Mich. Ct. App. 2021). · cites it 9× “And because venue is not constitutionally mandated, in the absence of a miscarriage of justice or deprivation of a constitutional right, MCL 600.1645 prohibits reversal of a conviction on the basis of a venue error alone.”
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