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

Mich. Comp. Laws § 600.2169 (2026)

Qualifications of expert witness in action alleging medical malpractice; determination; disqualification of expert witness; testimony on contingency fee basis as misdemeanor; limitations applicable to discovery.

✓ current as of July 2026
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REVISED JUDICATURE ACT OF 1961


Act 236 of 1961


600.2169 Qualifications of expert witness in action alleging medical malpractice; determination; disqualification of expert witness; testimony on contingency fee basis as misdemeanor; limitations applicable to discovery.

Sec. 2169.

    (1) In an action alleging medical malpractice, a person shall not give expert testimony on the appropriate standard of practice or care unless the person is licensed as a health professional in this state or another state and meets the following criteria:

    (a) If the party against whom or on whose behalf the testimony is offered is a specialist, specializes at the time of the occurrence that is the basis for the action in the same specialty as the party against whom or on whose behalf the testimony is offered. However, if the party against whom or on whose behalf the testimony is offered is a specialist who is board certified, the expert witness must be a specialist who is board certified in that specialty.

    (b) Subject to subdivision (c), during the year immediately preceding the date of the occurrence that is the basis for the claim or action, devoted a majority of his or her professional time to either or both of the following:

    (i) The active clinical practice of the same health profession in which the party against whom or on whose behalf the testimony is offered is licensed and, if that party is a specialist, the active clinical practice of that specialty.

    (ii) The instruction of students in an accredited health professional school or accredited residency or clinical research program in the same health profession in which the party against whom or on whose behalf the testimony is offered is licensed and, if that party is a specialist, an accredited health professional school or accredited residency or clinical research program in the same specialty.

    (c) If the party against whom or on whose behalf the testimony is offered is a general practitioner, the expert witness, during the year immediately preceding the date of the occurrence that is the basis for the claim or action, devoted a majority of his or her professional time to either or both of the following:

    (i) Active clinical practice as a general practitioner.

    (ii) Instruction of students in an accredited health professional school or accredited residency or clinical research program in the same health profession in which the party against whom or on whose behalf the testimony is offered is licensed.

    (2) In determining the qualifications of an expert witness in an action alleging medical malpractice, the court shall, at a minimum, evaluate all of the following:

    (a) The educational and professional training of the expert witness.

    (b) The area of specialization of the expert witness.

    (c) The length of time the expert witness has been engaged in the active clinical practice or instruction of the health profession or the specialty.

    (d) The relevancy of the expert witness's testimony.

    (3) This section does not limit the power of the trial court to disqualify an expert witness on grounds other than the qualifications set forth in this section.

    (4) In an action alleging medical malpractice, an expert witness shall not testify on a contingency fee basis. A person who violates this subsection is guilty of a misdemeanor.

    (5) In an action alleging medical malpractice, all of the following limitations apply to discovery conducted by opposing counsel to determine whether or not an expert witness is qualified:

    (a) Tax returns of the expert witness are not discoverable.

    (b) Family members of the expert witness shall not be deposed concerning the amount of time the expert witness spends engaged in the practice of his or her health profession.

    (c) A personal diary or calendar belonging to the expert witness is not discoverable. As used in this subdivision, "personal diary or calendar" means a diary or calendar that does not include listings or records of professional activities.

History: Add. 1986, Act 178, Eff. Oct. 1, 1986 ;-- Am. 1993, Act 78, Eff. Apr. 1, 1994

Constitutionality Notes:

    MCL 600.2169 is an enactment of substantive law. As such it does not impermissibly infringe the Supreme Court's constitutional rule-making authority over “practice and procedure.” McDougall v Schanz, 461 Mich 15; 597 NW2d 148 (1999).

Compiler's Notes:

    Section 3 of Act 178 of 1986 provides:

    “(1) Sections 2925b, 5805, 5838, and 5851 of Act No. 236 of the Public Acts of 1961, as amended by this amendatory act, shall not apply to causes of action arising before October 1, 1986.

    “(2) Sections 1483, 5838a, and 6304 of Act No. 236 of the Public Acts of 1961, as added by this amendatory act, shall apply to causes of action arising on or after October 1, 1986.

    “(3) Sections 1629, 1653, 2169, 2591, 2912c, 2912d, 2912e, 6098, 6301, 6303, 6305, 6306, 6307, 6309, and 6311 of Act No. 236 of the Public Acts of 1961, as added by this amendatory act, shall apply to cases filed on or after October 1, 1986.

    “(4) Sections 1651 and 6013 of Act No. 236 of the Public Acts of 1961, as amended by this amendatory act, shall not apply to cases filed before October 1, 1986.

    “(5) Chapter 49 of Act No. 236 of the Public Acts of 1961, as added by this amendatory act, shall apply to cases filed on or after January 1, 1987.

    “(6) Chapter 49a of Act No. 236 of the Public Acts of 1961, as added by this amendatory act, shall apply to cases filed in judicial circuits which are comprised of more than 1 county on or after July 1, 1990 and shall apply to cases filed in judicial circuits which are comprised of 1 county on or after October 1, 1988.”

Notes of Decisions
Cited in 237 cases (65 in the last 5 years), 1989–2026 · leading case: Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006).
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Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). · cites it 253× “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Halloran v. Bhan, 683 N.W.2d 129 (Mich. 2004). · cites it 70× “§ 600.2169, the standard-of-care witness would have to be a board-certified internist.”
Rock v. Crocker, 884 N.W.2d 227 (Mich. 2016). · cites it 26× “2912d(l) and MCL 600.2169. “[U]nder MCL 600.2912d(1), a plaintiff is required to file with the complaint an affidavit of merit signed by an expert who the plaintiffs attorney reasonably believes meets the requirements of MCL 600.”
Grossman v. Brown, 685 N.W.2d 198 (Mich. 2004). · cites it 34× “§ 600.2169 in order to sign plaintiff's affidavit of merit.”
Cox v. Eric J. Hartman, M.D., & Blue Water Obstetrics & Gynecology Prof'l Corp., 911 N.W.2d 219 (Mich. Ct. App. 2017). · cites it 13× “2912d(1) (governing affidavits of merit) ] and [ MCL 600.2169 (governing testimony at trial) ]" Sturgis , 268 Mich.”
Gonzalez v. St John Hosp. & Med. Ctr., 739 N.W.2d 392 (Mich. Ct. App. 2007). · cites it 35× “1 Defendants argued that because plaintiffs expert was a specialist and Vashi was a general practitioner, the expert was not qualified to offer testimony against Vashi under MCL 600.”
McDougall v. Schanz, 597 N.W.2d 148 (Mich. 1999). · cites it 25× “§ 600.2169; M.S.A. § 27A.2169, which provides strict requirements for the admission of expert testimony in medical malpractice cases brought against specialists, impermissibly infringes this Court's exclusive authority under Const.”
Nippa v. Botsford Gen. Hosp., 668 N.W.2d 628 (Mich. Ct. App. 2003). · cites it 43× “] We concluded that plaintiff's affidavit of merit in this medical-malpractice case was insufficient because it was not signed by a doctor who specializes or is board-certified in the same specialty as the doctors on whose conduct the action was based.”
Kiefer v. Markley, 769 N.W.2d 271 (Mich. Ct. App. 2009). · cites it 36× “Valauri devoted a sufficient amount of time to hand surgery in his practice to qualify as an expert witness under MCL 600.2169, which provides in relevant part as follows: (1) In an action alleging medical malpractice, a person shall not give expert testimony on the appropriate…”
Gay v. Select Specialty Hosp., 813 N.W.2d 354 (Mich. Ct. App. 2012). · cites it 27× “EXPERT’S PROFESSIONAL TIME UNDER MCL 600.2169 The salient question is whether Nurse Boggs devoted sufficient time in the active clinical practice of nursing or instruction in nursing to qualify as an expert witness under MCL 600.”
Woodard v. Custer, 702 N.W.2d 522 (Mich. 2005). · cites it 22× “2912d(1) that plaintiffs' proposed expert *524 witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs' affidavit of merit was sufficient.”
Bates v. Gilbert, 479 Mich. 451 (Mich. 2007). · cites it 27× “2912d(1) plaintiff’s counsel could have reasonably believed that plaintiff’s proposed expert witness, an ophthalmologist, was qualified to sign an affidavit of merit under MCL 600.2169 offered against defendant, an optometrist.”
Show all 237 citing cases →
— Mich. Comp. Laws § 600.2169(1) — 99 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Halloran v. Bhan, 683 N.W.2d 129 (Mich. 2004). “§ 600.2169, the standard-of-care witness would have to be a board-certified internist.”
Gonzalez v. St John Hosp. & Med. Ctr., 739 N.W.2d 392 (Mich. Ct. App. 2007). “1 Defendants argued that because plaintiffs expert was a specialist and Vashi was a general practitioner, the expert was not qualified to offer testimony against Vashi under MCL 600.”
Rock v. Crocker, 884 N.W.2d 227 (Mich. 2016). “2912d(l) and MCL 600.2169. “[U]nder MCL 600.2912d(1), a plaintiff is required to file with the complaint an affidavit of merit signed by an expert who the plaintiffs attorney reasonably believes meets the requirements of MCL 600.”
Grossman v. Brown, 685 N.W.2d 198 (Mich. 2004). “§ 600.2169 in order to sign plaintiff's affidavit of merit.”
— Mich. Comp. Laws § 600.2169(1)(a) — 81 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Halloran v. Bhan, 683 N.W.2d 129 (Mich. 2004). “§ 600.2169, the standard-of-care witness would have to be a board-certified internist.”
Rock v. Crocker, 884 N.W.2d 227 (Mich. 2016). “2912d(l) and MCL 600.2169. “[U]nder MCL 600.2912d(1), a plaintiff is required to file with the complaint an affidavit of merit signed by an expert who the plaintiffs attorney reasonably believes meets the requirements of MCL 600.”
Nippa v. Botsford Gen. Hosp., 668 N.W.2d 628 (Mich. Ct. App. 2003). “] We concluded that plaintiff's affidavit of merit in this medical-malpractice case was insufficient because it was not signed by a doctor who specializes or is board-certified in the same specialty as the doctors on whose conduct the action was based.”
Nippa v. Botsford Gen. Hosp., 651 N.W.2d 103 (Mich. Ct. App. 2002).
— Mich. Comp. Laws § 600.2169(1)(b) — 46 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Cox v. Eric J. Hartman, M.D., & Blue Water Obstetrics & Gynecology Prof'l Corp., 911 N.W.2d 219 (Mich. Ct. App. 2017). “2912d(1) (governing affidavits of merit) ] and [ MCL 600.2169 (governing testimony at trial) ]" Sturgis , 268 Mich.”
Kiefer v. Markley, 769 N.W.2d 271 (Mich. Ct. App. 2009). “Valauri devoted a sufficient amount of time to hand surgery in his practice to qualify as an expert witness under MCL 600.2169, which provides in relevant part as follows: (1) In an action alleging medical malpractice, a person shall not give expert testimony on the appropriate…”
Woodard v. Custer, 702 N.W.2d 522 (Mich. 2005). “2912d(1) that plaintiffs' proposed expert *524 witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs' affidavit of merit was sufficient.”
McElhaney v. Harper-Hutzel Hosp., 711 N.W.2d 795 (Mich. Ct. App. 2006).
— Mich. Comp. Laws § 600.2169(1)(b)(i) — 23 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
McElhaney v. Harper-Hutzel Hosp., 711 N.W.2d 795 (Mich. Ct. App. 2006).
Halloran v. Bhan, 683 N.W.2d 129 (Mich. 2004). “§ 600.2169, the standard-of-care witness would have to be a board-certified internist.”
Hamilton v. Kuligowski, 684 N.W.2d 366 (Mich. Ct. App. 2004).
Bates v. Gilbert, 479 Mich. 451 (Mich. 2007). “2912d(1) plaintiff’s counsel could have reasonably believed that plaintiff’s proposed expert witness, an ophthalmologist, was qualified to sign an affidavit of merit under MCL 600.2169 offered against defendant, an optometrist.”
— Mich. Comp. Laws § 600.2169(1)(b)(ii) — 3 cases
Valerie Fenwick v. Louis L Sobol Md (Mich. Ct. App. 2023).
Kelley Crego v. Edward W Sparrow Hosp. Assn (Mich. Ct. App. 2019).
Katie M Howard-Reed v. Barry Braver Do (Mich. Ct. App. 2022).
— Mich. Comp. Laws § 600.2169(1)(c) — 9 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Saffian v. Simmons, 704 N.W.2d 722 (Mich. Ct. App. 2005).
Gonzalez v. St. John Hosp. & Med. Ctr., 745 N.W.2d 749 (Mich. 2008).
Kelley Crego v. Edward W Sparrow Hosp. Assn (Mich. Ct. App. 2019).
Michele Price v. Eleni Callis Dds (Mich. Ct. App. 2019).
— Mich. Comp. Laws § 600.2169(1)(c)(i) — 1 case
Kelley Crego v. Edward W Sparrow Hosp. Assn (Mich. Ct. App. 2019).
— Mich. Comp. Laws § 600.2169(2) — 32 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Halloran v. Bhan, 683 N.W.2d 129 (Mich. 2004). “§ 600.2169, the standard-of-care witness would have to be a board-certified internist.”
Craig v. Oakwood Hosp., 684 N.W.2d 296 (Mich. 2004).
Nippa v. Botsford Gen. Hosp., 651 N.W.2d 103 (Mich. Ct. App. 2002).
Gonzalez v. St John Hosp. & Med. Ctr., 739 N.W.2d 392 (Mich. Ct. App. 2007). “1 Defendants argued that because plaintiffs expert was a specialist and Vashi was a general practitioner, the expert was not qualified to offer testimony against Vashi under MCL 600.”
— Mich. Comp. Laws § 600.2169(2)(a) — 2 cases
STURGIS BANK & TRUST CO. v. Hillsdale Cmty. Health Ctr., 735 N.W.2d 206 (Mich. 2007).
Est. of Jason a Blackwell v. St Mary's of Michigan (Mich. Ct. App. 2020).
— Mich. Comp. Laws § 600.2169(2)(c) — 1 case
Kelley Crego v. Edward W Sparrow Hosp. Assn (Mich. Ct. App. 2019).
— Mich. Comp. Laws § 600.2169(2)(d) — 1 case
Halloran v. Bhan, 683 N.W.2d 129 (Mich. 2004). “§ 600.2169, the standard-of-care witness would have to be a board-certified internist.”
— Mich. Comp. Laws § 600.2169(3) — 8 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Antonio Selliman v. Jeffrey J Colton Md (Mich. 2024).
Est. of Linda Horn v. Michael J Swofford Do (Mich. 2024).
Johnathan Myers v. Bd. of Hosp. Managers for City of Flint (Mich. Ct. App. 2024).
20241212_C357931_69_357931O.Opn.Pdf (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 600.2169(4) — 1 case
Dupree v. Malpractice Rsch., Inc, 445 N.W.2d 498 (Mich. Ct. App. 1989).
— Mich. Comp. Laws § 600.2169(5) — 1 case
Yani Sanharib Warda v. Farm Bureau Gen. Ins. Co. (Mich. Ct. App. 2024).
— Mich. Comp. Laws § 600.2169(5)(a) — 4 cases
Kathleen Micheli v. Michigan Auto. Ins Placement Facility (Mich. Ct. App. 2022).
C Kathleen Micheli v. Michigan Auto. Ins Placement Facility (Mich. Ct. App. 2022).
Kathleen Micheli v. Michigan Auto. Ins Placement Facility (Mich. Ct. App. 2022).
C Kathleen Micheli v. Michigan Auto. Ins Placement Facility (Mich. Ct. App. 2022).
— Mich. Comp. Laws § 600.2169(a) — 1 case
Joy a Jilek v. Carlin C Stockson Md (Mich. 2011).
— Mich. Comp. Laws § 600.2169(b) — 1 case
Brown v. Hayes, 716 N.W.2d 13 (Mich. Ct. App. 2006).
— Mich. Comp. Laws § 600.2169(b)(ii) — 1 case
Est. of Amos Jones v. Botsford Continuing Care Corp. (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 600.2169(l)(a) — 20 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Rock v. Crocker, 884 N.W.2d 227 (Mich. 2016). “2912d(l) and MCL 600.2169. “[U]nder MCL 600.2912d(1), a plaintiff is required to file with the complaint an affidavit of merit signed by an expert who the plaintiffs attorney reasonably believes meets the requirements of MCL 600.”
Halloran v. Bhan, 683 N.W.2d 129 (Mich. 2004). “§ 600.2169, the standard-of-care witness would have to be a board-certified internist.”
Gonzalez v. St John Hosp. & Med. Ctr., 739 N.W.2d 392 (Mich. Ct. App. 2007). “1 Defendants argued that because plaintiffs expert was a specialist and Vashi was a general practitioner, the expert was not qualified to offer testimony against Vashi under MCL 600.”
Nippa v. Botsford Gen. Hosp., 668 N.W.2d 628 (Mich. Ct. App. 2003). “] We concluded that plaintiff's affidavit of merit in this medical-malpractice case was insufficient because it was not signed by a doctor who specializes or is board-certified in the same specialty as the doctors on whose conduct the action was based.”
— Mich. Comp. Laws § 600.2169(l)(b) — 7 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Gay v. Select Specialty Hosp., 813 N.W.2d 354 (Mich. Ct. App. 2012). “EXPERT’S PROFESSIONAL TIME UNDER MCL 600.2169 The salient question is whether Nurse Boggs devoted sufficient time in the active clinical practice of nursing or instruction in nursing to qualify as an expert witness under MCL 600.”
Kiefer v. Markley, 769 N.W.2d 271 (Mich. Ct. App. 2009). “Valauri devoted a sufficient amount of time to hand surgery in his practice to qualify as an expert witness under MCL 600.2169, which provides in relevant part as follows: (1) In an action alleging medical malpractice, a person shall not give expert testimony on the appropriate…”
Gonzalez v. St John Hosp. & Med. Ctr., 739 N.W.2d 392 (Mich. Ct. App. 2007). “1 Defendants argued that because plaintiffs expert was a specialist and Vashi was a general practitioner, the expert was not qualified to offer testimony against Vashi under MCL 600.”
Rock v. Crocker, 884 N.W.2d 227 (Mich. 2016). “2912d(l) and MCL 600.2169. “[U]nder MCL 600.2912d(1), a plaintiff is required to file with the complaint an affidavit of merit signed by an expert who the plaintiffs attorney reasonably believes meets the requirements of MCL 600.”
— Mich. Comp. Laws § 600.2169(l)(b)(i) — 5 cases
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Halloran v. Bhan, 683 N.W.2d 129 (Mich. 2004). “§ 600.2169, the standard-of-care witness would have to be a board-certified internist.”
Gay v. Select Specialty Hosp., 813 N.W.2d 354 (Mich. Ct. App. 2012). “EXPERT’S PROFESSIONAL TIME UNDER MCL 600.2169 The salient question is whether Nurse Boggs devoted sufficient time in the active clinical practice of nursing or instruction in nursing to qualify as an expert witness under MCL 600.”
Bates v. Gilbert, 479 Mich. 451 (Mich. 2007). “2912d(1) plaintiff’s counsel could have reasonably believed that plaintiff’s proposed expert witness, an ophthalmologist, was qualified to sign an affidavit of merit under MCL 600.2169 offered against defendant, an optometrist.”
Brown v. Hayes, 716 N.W.2d 13 (Mich. Ct. App. 2006).
— Mich. Comp. Laws § 600.2169(l)(b)(ii) — 1 case
Gay v. Select Specialty Hosp., 813 N.W.2d 354 (Mich. Ct. App. 2012). “EXPERT’S PROFESSIONAL TIME UNDER MCL 600.2169 The salient question is whether Nurse Boggs devoted sufficient time in the active clinical practice of nursing or instruction in nursing to qualify as an expert witness under MCL 600.”
— Mich. Comp. Laws § 600.2169(l)(c) — 5 cases
Gonzalez v. St John Hosp. & Med. Ctr., 739 N.W.2d 392 (Mich. Ct. App. 2007). “1 Defendants argued that because plaintiffs expert was a specialist and Vashi was a general practitioner, the expert was not qualified to offer testimony against Vashi under MCL 600.”
Johanna Woodard v. Univ. of Mich Med. Ctr, 476 Mich. 545 (Mich. 2006). “2912d(1) that plaintiffs’ proposed expert witness was qualified under MCL 600.2169 to testify against the defendant physician, and, thus, that plaintiffs’ affidavit of merit was sufficient.”
Robins v. Garg, 741 N.W.2d 49 (Mich. Ct. App. 2007).
Rock v. Crocker, 884 N.W.2d 227 (Mich. 2016). “2912d(l) and MCL 600.2169. “[U]nder MCL 600.2912d(1), a plaintiff is required to file with the complaint an affidavit of merit signed by an expert who the plaintiffs attorney reasonably believes meets the requirements of MCL 600.”
Robins v. Garg, 716 N.W.2d 318 (Mich. Ct. App. 2006).
— Mich. Comp. Laws § 600.2169(l)(c)(i) — 1 case
Robins v. Garg, 741 N.W.2d 49 (Mich. Ct. App. 2007).
— Mich. Comp. Laws § 600.2169(lXb)(i) — 1 case
Mcdougall v. Eliuk, 554 N.W.2d 56 (Mich. Ct. App. 1996).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.