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

Mich. Comp. Laws § 600.2932 (2026)

Quieting title; interest of plaintiff; action by mortgagee; establishment of title; tenancy in common; actions.

✓ current as of July 2026
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REVISED JUDICATURE ACT OF 1961


Act 236 of 1961


600.2932 Quieting title; interest of plaintiff; action by mortgagee; establishment of title; tenancy in common; actions.

Sec. 2932.

    (1) Any person, whether he is in possession of the land in question or not, who claims any right in, title to, equitable title to, interest in, or right to possession of land, may bring an action in the circuit courts against any other person who claims or might claim any interest inconsistent with the interest claimed by the plaintiff, whether the defendant is in possession of the land or not.

    (2) No action may be maintained under subsection (1) by a mortgagee, his assigns, or representatives for recovery of the mortgaged premises, until the title to the mortgaged premises has become absolute, or by a person for the recovery of possession of premises, which were sold on land contracted, to whom relief is available under subdivision (1) of section 5634.

    (3) If the plaintiff established his title to the lands, the defendant shall be ordered to release to the plaintiff all claims thereto. In an appropriate case the court may issue a writ of possession or restitution to the sheriff or other proper officer of any county in this state in which the premises recovered are situated.

    (4) Any tenant or tenants in common who recovers any undivided interest in lands in an action under subsection (1) against a person or persons who may be in possession thereof, but who does not show in the trial of such action that he or they have any interest therein or title thereto, may take possession of the entire premises subject to all of the rights and interest of the other tenant or tenants in common therein.

    (5) Actions under this section are equitable in nature.

History: 1961, Act 236, Eff. Jan. 1, 1963 ;-- Am. 1964, Act 8, Eff. Aug. 28, 1964

Notes of Decisions
Cited in 146 cases (51 in the last 5 years), 1965–2026 · leading case: Adams v. Adams, 742 N.W.2d 399 (Mich. Ct. App. 2007).
Sort: Relevance Newest Treatment
Adams v. Adams, 742 N.W.2d 399 (Mich. Ct. App. 2007). · cites it 17× “She asserts that the true gravamen of her complaint was to quiet title under MCL 600.2932, and that the trial court therefore should have applied the 15-year limitations period of MCL 600.”
New Prods. Corp. v. Harbor Shores Bhbt Land Dev., 866 N.W.2d 850 (Mich. Ct. App. 2014). · cites it 37× “Relying on the language in MCL 600.2932 and the related court rule, MCR 3.”
Beach v. Lima Twp., 802 N.W.2d 1 (Mich. 2011). · cites it 14× “35 See MCL 600.2932. 36 As early as 1937, this Court acknowledged the distinction between obtaining title by adverse possession and vacating a plat.”
Richards v. Tibaldi, 726 N.W.2d 770 (Mich. Ct. App. 2007). · cites it 3× “411(H) and MCL 600.2932(3) (“the defendant shall be ordered to release .”
Wilmington Saving Fund Soc'y Fsb v. Roger Duane Clare, 919 N.W.2d 420 (Mich. Ct. App. 2018). · cites it 3× “] This litigation involves an action to quiet title filed by plaintiff because the parties dispute their respective interests in the condominium unit.”
People v. March, 499 Mich. 389 (Mich. 2016). “That statute currently is codified at MCL 600.2932(2), which states that “[n]o action may be maintained [for ejectment] by a mortgagee, his assigns, or representatives for recovery of the mortgaged premises, until the title to the mortgaged premises has become absolute.”
Garcia v. Fed. Nat'l Mortg. Ass'n, 782 F.3d 736 (6th Cir. 2015). · cites it 2× “4 Plaintiffs brought four claims in their complaint: (1) Quiet Title pursuant to Mich. Comp. Laws § 600.2932 ; (2) violations of Fifth and Fourteenth Amendment Due Process Rights; (3) illegal/improper foreclosure and sheriff’s sale pursuant to Mich.”
Wayne Cnty. Treasurer v. Westhaven Manor Ltd. Dividend Hous. Ass'n, 698 N.W.2d 879 (Mich. Ct. App. 2005). · cites it 2× “However, unlike mortgage foreclosure actions or civil actions to determine interests in land under MCL 600.2932, the court rules contain no special rules for tax foreclosure actions.”
Morse v. Colitti, 896 N.W.2d 15 (Mich. Ct. App. 2016). “, plaintiffs portion of the Walk, and requested that the trial court determine that plaintiff has ownership of the Walk to the centerline as well as grant injunctive relief to rectify the alleged seizure.”
Sumpter v. United States, 302 F. Supp. 2d 707 (E.D. Mich. 2004). · cites it 4× “The Michigan legislature has established a statutory cause of action to quiet title by Mich. Comp. Laws § 600.2932 (1), which states that “[a]ny person, whether he is in possession of the land in question or not, who claims any right in, title to, equitable title to, interest…”
Hall v. Hanson, 664 N.W.2d 796 (Mich. Ct. App. 2003). · cites it 4× “In Hill, plaintiff Raymond Hill brought a quiet title action under MCL 600.2932 against Houghton Township and Keweenaw County, alleging that he had acquired title to a piece of property described as a “public square” through adverse possession.”
Steward v. Panek, 652 N.W.2d 232 (Mich. Ct. App. 2002). “Further, MCL 600.2932(1) provides: Any person, whether he is in possession of the land in question or not, who claims any right in, title to, equitable title to, interest in, or right to possession of land, may bring an action in the circuit courts against any other person who…”
Show all 146 citing cases →
— Mich. Comp. Laws § 600.2932(1) — 65 cases
Adams v. Adams, 742 N.W.2d 399 (Mich. Ct. App. 2007). “She asserts that the true gravamen of her complaint was to quiet title under MCL 600.2932, and that the trial court therefore should have applied the 15-year limitations period of MCL 600.”
New Prods. Corp. v. Harbor Shores Bhbt Land Dev., 866 N.W.2d 850 (Mich. Ct. App. 2014). “Relying on the language in MCL 600.2932 and the related court rule, MCR 3.”
Wilmington Saving Fund Soc'y Fsb v. Roger Duane Clare, 919 N.W.2d 420 (Mich. Ct. App. 2018). “] This litigation involves an action to quiet title filed by plaintiff because the parties dispute their respective interests in the condominium unit.”
Beach v. Lima Twp., 802 N.W.2d 1 (Mich. 2011). “35 See MCL 600.2932. 36 As early as 1937, this Court acknowledged the distinction between obtaining title by adverse possession and vacating a plat.”
Steward v. Panek, 652 N.W.2d 232 (Mich. Ct. App. 2002). “Further, MCL 600.2932(1) provides: Any person, whether he is in possession of the land in question or not, who claims any right in, title to, equitable title to, interest in, or right to possession of land, may bring an action in the circuit courts against any other person who…”
— Mich. Comp. Laws § 600.2932(2) — 3 cases
People v. March, 499 Mich. 389 (Mich. 2016). “That statute currently is codified at MCL 600.2932(2), which states that “[n]o action may be maintained [for ejectment] by a mortgagee, his assigns, or representatives for recovery of the mortgaged premises, until the title to the mortgaged premises has become absolute.”
New Prods. Corp. v. Harbor Shores Bhbt Land Dev., 866 N.W.2d 850 (Mich. Ct. App. 2014). “Relying on the language in MCL 600.2932 and the related court rule, MCR 3.”
Jp Morgan Chase Bank Na v. Joseph H Mammo (Mich. Ct. App. 2014).
— Mich. Comp. Laws § 600.2932(3) — 8 cases
Richards v. Tibaldi, 726 N.W.2d 770 (Mich. Ct. App. 2007). “411(H) and MCL 600.2932(3) (“the defendant shall be ordered to release .”
New Prods. Corp. v. Harbor Shores Bhbt Land Dev., 866 N.W.2d 850 (Mich. Ct. App. 2014). “Relying on the language in MCL 600.2932 and the related court rule, MCR 3.”
Charles Louis Van Fleteren Jr v. Thomas J Shugar (Mich. Ct. App. 2019).
Eric Bradley v. Linda Frye-Chaiken (Mich. Ct. App. 2021).
Rovin Vinod v. Pauline Props. LLC (Mich. Ct. App. 2022).
— Mich. Comp. Laws § 600.2932(5) — 20 cases
New Prods. Corp. v. Harbor Shores Bhbt Land Dev., 866 N.W.2d 850 (Mich. Ct. App. 2014). “Relying on the language in MCL 600.2932 and the related court rule, MCR 3.”
Adams v. Adams, 742 N.W.2d 399 (Mich. Ct. App. 2007). “She asserts that the true gravamen of her complaint was to quiet title under MCL 600.2932, and that the trial court therefore should have applied the 15-year limitations period of MCL 600.”
Tray v. Whitney, 192 N.W.2d 628 (Mich. Ct. App. 1971).
Kraus v. Gerrish Twp., 517 N.W.2d 756 (Mich. Ct. App. 1994).
Hall v. Hanson, 664 N.W.2d 796 (Mich. Ct. App. 2003). “In Hill, plaintiff Raymond Hill brought a quiet title action under MCL 600.2932 against Houghton Township and Keweenaw County, alleging that he had acquired title to a piece of property described as a “public square” through adverse possession.”
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