Michigan Compiled Laws

Mich. Comp. Laws § 600.2549 (2026)

Depositions and certified copies; fees taxable as costs.

✓ current as of July 2026

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REVISED JUDICATURE ACT OF 1961

Act 236 of 1961

600.2549 Depositions and certified copies; fees taxable as costs.

Sec. 2549.

Reasonable and actual fees paid for depositions of witnesses filed in any clerk's office and for the certified copies of documents or papers recorded or filed in any public office shall be allowed in the taxation of costs only if, at the trial or when damages were assessed, the depositions were read in evidence, except for impeachment purposes, or the documents or papers were necessarily used.

History: 1961, Act 236, Eff. Jan. 1, 1963 ;-- Am. 1984, Act 278, Eff. Jan. 1, 1985

Notes of Decisions

Cited in 28 cases (2 in the last 5 years), 1974–2026 · leading case: Elia v. Hazen, 619 N.W.2d 1 (Mich. Ct. App. 2000).

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Elia v. Hazen, 619 N.W.2d 1 (Mich. Ct. App. 2000). · cites it 20× “MCL 600.2549; MSA 27A.2549 provides: Reasonable and actual fees paid for depositions of witnesses filed in any clerk's office and for the certified copies of documents or papers recorded or filed in any public office shall be allowed in the taxation of costs only if, at the…”

Beach v. State Farm Mut. Auto. Ins., 550 N.W.2d 580 (Mich. Ct. App. 1996). · cites it 8× “§ 600.2549; M.S.A. § 27A.2549 provide the statutory basis for his recovery of costs relating to copies of certain records that plaintiff's experts allegedly used to prepare for trial.”

Portelli v. I R Constr. Prods. Co., 554 N.W.2d 591 (Mich. Ct. App. 1996). · cites it 10× “Construction filed a motion to tax costs against plaintiff, seeking costs for four depositions necessarily used to procure summary disposition pursuant to MCR 2.”

Guerrero v. Smith, 761 N.W.2d 723 (Mich. Ct. App. 2008). · cites it 2× “315(1); MCL 600.2549. The trial court erred by allowing defendants to tax $3,629.”

Van Elslander v. Thomas Sebold & Assocs., Inc., 823 N.W.2d 843 (Mich. Ct. App. 2012). · cites it 3× “MCL 600.2549. MCL 600.2543(2) and MCR 7.219(F)(3).”

Lavene v. Winnebago Indus., 702 N.W.2d 652 (Mich. Ct. App. 2005). · cites it 2× “271(4), is limited by the MCL 600.2549 requirements for depositions).”

Kernen v. Homestead Dev. Co., 653 N.W.2d 634 (Mich. Ct. App. 2002). “Furthermore, the court rule differs from MCL 600.2549 and does not require that the deposition testimony of the expert be used at trial before the trial court may award fees under the rule.”

Adair v. Michigan, 298 Mich. App. 383 (Mich. Ct. App. 2012). · cites it 2× “” The Court in LaVene used this rule to conclude that the trial court did not err by awarding costs arising from three depositions when those depositions were filed with the court clerk and admitted into evidence as required by MCL 600.2549. We decline to take any guidance from…”

Gentris v. State Farm Mut. Auto. Ins., 297 Mich. App. 354 (Mich. Ct. App. 2012). “2405 (costs and items taxable), MCL 600.2549 (depositions, certified copies, and fees taxable as costs), MCL 600.”

Rickwalt v. Richfield Lakes Corp., 633 N.W.2d 418 (Mich. Ct. App. 2001). “[MCL 600.2549.] In this case, the parties apparently do not dispute that plaintiff filed notices of the takings or completions of the seven depositions at issue, but that plaintiff did not file with the trial court clerk the seven depositions themselves.”

Ron Vanalstine v. Land O'Lakes Purina Feeds LLC, 929 N.W.2d 789 (Mich. Ct. App. 2018). “MCL 600.2549. Although defendant asserts that the deposition transcripts were filed in the clerk's office, a review of the register of actions does not support this assertion.”

Morrison v. City of East Lansing, 660 N.W.2d 395 (Mich. Ct. App. 2003). “271(4) provides that if relief is obtained in an action against a public body for not complying with the oma, that relief shall include “court costs and actual attorney fees,” we conclude, as did the trial court, that the deposition costs in the instant case are not included in…”

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