REVISED JUDICATURE ACT OF 1961
Act 236 of 1961
600.2907a Violation of MCL 565.25; liability to owner of encumbered property; penalty.
Sec. 2907a.
(1) A person who violates section 25 of chapter 65 of the Revised Statutes of 1846, being section 565.25 of the Michigan Compiled Laws, by encumbering property through the recording of a document without lawful cause with the intent to harass or intimidate any person is liable to the owner of the property encumbered for all of the following:
(a) All of the costs incurred in bringing an action under section 25 of chapter 65 of the Revised Statutes of 1846, including actual attorney fees.
(b) All damages the owner of the property may have sustained as a result of the filing of the encumbrance.
(c) Exemplary damages.
(2) A person who violates section 25 of chapter 65 of the Revised Statutes of 1846, by encumbering property through the recording of a document without lawful cause with the intent to harass or intimidate any person is guilty of a felony punishable by imprisonment for not more than 3 years or a fine of not more than $5,000.00, or both.
History: Add. 1996, Act 527, Eff. Mar. 31, 1997
Notes of Decisions
Cited in
17
cases (
3 in the last 5 years), 1998–2025 · leading case:
People v. Cynar
People v. Cynar (2002)
michctapp · cites it 13×
“This case involves the criminal charges filed against defendant: twelve counts of encumbering real property without lawful cause in violation of MCL 600.2907a. Enacted as part of the Revised Judicature Act (RJA), MCL 600.”
B & B Investment Group v. Gitler (1998)
michctapp · cites it 2×
“543 and MCL 600.2907a; MSA 27A.2907a, which took effect March 31, 1997, while this appeal was pending.”
People v. Johnson-E1 (2013)
michctapp · cites it 2×
“249, and encumbering real property without lawful cause, MCL 600.2907a(2), based on an “Affidavit of Allodial Title” that he authored, signed, and recorded with the Wayne County Register of Deeds for a parcel of property in which he had no ownership or other interest.”
Baker v. Residential Funding Co. (2012)
mied · cites it 2×
“The second count is titled “Defendants Perpetrated a Fraud Upon the 14A District Court and the 22nd Circuit Court Thereby Wrongfully Obtaining a Consent Judgment in Violation of Mich. Comp. Laws 600.2907a.” Id. ¶¶ 35-82.”
Brown Bark I, L.P. v. Traverse City Light & Power Department (2010)
miwd · cites it 2×
“(5) A person who is not exempt under subsection (2) who encumbers property through the recording of an instrument listed under subsection (1) without lawful cause with the intent to harass or intimidate any person is liable for the penalties set forth in section 2907a of the…”
Details Automotive Finishes LLC v. Four Childrens Enterprises LLC (2022)
michctapp · cites it 8×
“The trial court awarded plaintiff damages against Ware and FCE for slander of title pursuant to MCL 600.2907a(1), which provides as follows: (1) A person who violates section 25 of chapter 65 of the Revised Statutes of 1846, being section 565.”
20251114_C369872_38_369872.Opn_Order.Pdf (2025)
michctapp · cites it 4×
“25 of the Michigan Compiled Laws, by encumbering property through the recording of a document without lawful cause with the intent to harass or intimidate any person is liable to the owner of the property encumbered for all of the following: (a) All of the costs incurred in…”
Main Street Lofts Condominium Association v. Oscar Franco Parodi (2023)
michctapp · cites it 2×
“2907a(1), which provides that a person who “encumber[s] property through the recording of a document without lawful cause with the intent to harass or intimidate any person is liable to the owner of the property” for monetary and exemplary damages. Plaintiff and CMA argued that,…”
— Mich. Comp. Laws § 600.2907a(1) — 4 cases
Details Automotive Finishes LLC v. Four Childrens Enterprises LLC (2022)
michctapp
“The trial court awarded plaintiff damages against Ware and FCE for slander of title pursuant to MCL 600.2907a(1), which provides as follows: (1) A person who violates section 25 of chapter 65 of the Revised Statutes of 1846, being section 565.”
Main Street Lofts Condominium Association v. Oscar Franco Parodi (2023)
michctapp
“2907a(1), which provides that a person who “encumber[s] property through the recording of a document without lawful cause with the intent to harass or intimidate any person is liable to the owner of the property” for monetary and exemplary damages. Plaintiff and CMA argued that,…”
— Mich. Comp. Laws § 600.2907a(1)(b) — 1 case
Details Automotive Finishes LLC v. Four Childrens Enterprises LLC (2022)
michctapp
“The trial court awarded plaintiff damages against Ware and FCE for slander of title pursuant to MCL 600.2907a(1), which provides as follows: (1) A person who violates section 25 of chapter 65 of the Revised Statutes of 1846, being section 565.”
— Mich. Comp. Laws § 600.2907a(1)(c) — 1 case
Details Automotive Finishes LLC v. Four Childrens Enterprises LLC (2022)
michctapp
“The trial court awarded plaintiff damages against Ware and FCE for slander of title pursuant to MCL 600.2907a(1), which provides as follows: (1) A person who violates section 25 of chapter 65 of the Revised Statutes of 1846, being section 565.”
— Mich. Comp. Laws § 600.2907a(2) — 3 cases
People v. Cynar (2002)
michctapp
“This case involves the criminal charges filed against defendant: twelve counts of encumbering real property without lawful cause in violation of MCL 600.2907a. Enacted as part of the Revised Judicature Act (RJA), MCL 600.”
People v. Johnson-E1 (2013)
michctapp
“249, and encumbering real property without lawful cause, MCL 600.2907a(2), based on an “Affidavit of Allodial Title” that he authored, signed, and recorded with the Wayne County Register of Deeds for a parcel of property in which he had no ownership or other interest.”
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