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

Mich. Comp. Laws § 600.2102 (2026)

Affidavit taken in other state or country; authentication.

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REVISED JUDICATURE ACT OF 1961


Act 236 of 1961


600.2102 Affidavit taken in other state or country; authentication.

Sec. 2102.

    If by law the affidavit of a person residing in another state of the United States or in a foreign country is required or may be received in an action or judicial proceeding in this state, to entitle the affidavit to be read, it must be authenticated under section 25a of the Michigan law on notarial acts, 2003 PA 238, MCL 55.285a, or be an unsworn declaration executed under chapter 21A.

History: 1961, Act 236, Eff. Jan. 1, 1963 ;-- Am. 2012, Act 361, Eff. Apr. 1, 2013 ;-- Am. 2018, Act 362, Eff. Mar. 12, 2019

Notes of Decisions
Cited in 16 cases, 1970–2018 · leading case: Apsey v. Mem'l Hosp., 730 N.W.2d 695 (Mich. 2007).
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Apsey v. Mem'l Hosp., 730 N.W.2d 695 (Mich. 2007). · cites it 105× “He concluded that the URAA was a response to advances in technology and that the Legislature intended both it and MCL 600.2102 to provide legal methods of authenticating out-of-state affidavits.”
Apsey v. Mem'l Hosp., 702 N.W.2d 870 (Mich. Ct. App. 2005). · cites it 94× “This seems to create logistical problems in that affidavits typically have the potential of ending up in a judicial proceeding, sometimes years after the notarial act was performed, although litigation was not anticipated at the time the affidavit was notarized.”
Vanslembrouck v. Halperin, 747 N.W.2d 311 (Mich. Ct. App. 2008). · cites it 18× “Pursuant to MCL 600.2102, the signature of an out-of-state notary public must be authenticated.”
Kaczynski v. Anderson, 731 N.W.2d 442 (Mich. Ct. App. 2007). · cites it 17× “” MCL 600.2102 states, “[W]here by law the affidavit of any person residing in another state .”
Tim Edward Brugger II v. Midland Cnty. Bd of Road Commissioners, 920 N.W.2d 388 (Mich. Ct. App. 2018). · cites it 5× “2d 699 (1970), the Court agreed that the relevant affidavit did not satisfy MCL 600.2102 but concluded that such an error could be corrected nunc pro tunc and was not dispositive of the case.”
Tousey v. Brennan, 739 N.W.2d 128 (Mich. Ct. App. 2007). · cites it 5× “See Apsey v Mem Hosp, 477 Mich 120; 730 NW2d 695 (2007) (holding that the special-certification provisions of MCL 600.2102[4] are merely alternative means of authenticating out-of-state affidavits).”
White v. Barbara Ann Karmanos Cancer Inst., 274 Mich. App. 801 (Mich. Ct. App. 2007). · cites it 20× “This depends on interpretation of MCL 600.2102, governing affidavits taken outside Michigan, and the interplay between that statute and Michigan’s Uniform Recognition of Acknowledgments Act (URAA), *803 MCL 565.”
Long v. Adams, 411 F. Supp. 2d 701 (E.D. Mich. 2006). · cites it 2× “” Mich. Comp. Laws § 600.2102 . The second, which became effective in 1970 when Michigan adopted the Uniform Recognition of Acknowledgments Act, provides that an out-of-state notary’s signature in his or her own state is as valid as if the notary had performed the act in…”
White v. Barbara Ann Karmanos Cancer Inst., 743 N.W.2d 225 (Mich. Ct. App. 2007). · cites it 22× “This depends on interpretation of MCL 600.2102, governing affidavits taken outside Michigan, and the interplay between that statute and Michigan's Uniform Recognition of Acknowledgments Act (URAA), MCL 565.”
Wallace v. Wallace, 179 N.W.2d 699 (Mich. Ct. App. 1970). · cites it 2× “4 The husband’s petition was verified as required by the court rule, GCR 1963, 725, but the notary’s signature was not authenticated in the manner required by RJA § 2102 (MCLA § 600.2102 [Stat Ann 1962 Rev § 27A.”
White v. Barbara Ann Karmanos Cancer Inst., 276 Mich. App. 295 (Mich. Ct. App. 2007). · cites it 2× “While the conflict panel was pending, our Supreme Court reversed this Court’s decision in Apsey and held that the URAA and MCL 600.2102 provide alternative methods for using out-of-state affidavits.”
Tim Edward Brugger II v. Midland Cnty. Bd of Road Commissioners, No. 337394 (Mich. Ct. App. May 15, 2018). · cites it 3× “However, the defendant argued that the affidavit was not effective in Michigan because it did not satisfy MCL 600.2102(4). Id. at 125 . That statute required that for an out-of-state affidavit to be effective in Michigan, it must be accompanied by a certification carrying the…”
Show all 16 citing cases →
Mich. Comp. Laws § 600.2102(4): 13 cases
Apsey v. Mem'l Hosp., 730 N.W.2d 695 (Mich. 2007). “He concluded that the URAA was a response to advances in technology and that the Legislature intended both it and MCL 600.2102 to provide legal methods of authenticating out-of-state affidavits.”
Apsey v. Mem'l Hosp., 702 N.W.2d 870 (Mich. Ct. App. 2005). “This seems to create logistical problems in that affidavits typically have the potential of ending up in a judicial proceeding, sometimes years after the notarial act was performed, although litigation was not anticipated at the time the affidavit was notarized.”
Vanslembrouck v. Halperin, 747 N.W.2d 311 (Mich. Ct. App. 2008). “Pursuant to MCL 600.2102, the signature of an out-of-state notary public must be authenticated.”
Kaczynski v. Anderson, 731 N.W.2d 442 (Mich. Ct. App. 2007). “” MCL 600.2102 states, “[W]here by law the affidavit of any person residing in another state .”
Tim Edward Brugger II v. Midland Cnty. Bd of Road Commissioners, 920 N.W.2d 388 (Mich. Ct. App. 2018). “2d 699 (1970), the Court agreed that the relevant affidavit did not satisfy MCL 600.2102 but concluded that such an error could be corrected nunc pro tunc and was not dispositive of the case.”
Mich. Comp. Laws § 600.2102(d): 1 case
Apsey v. Mem'l Hosp., 702 N.W.2d 870 (Mich. Ct. App. 2005). “This seems to create logistical problems in that affidavits typically have the potential of ending up in a judicial proceeding, sometimes years after the notarial act was performed, although litigation was not anticipated at the time the affidavit was notarized.”
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