Michigan Compiled Laws
Mich. Comp. Laws § 600.4545 (2026)
Election fraud or error; circuit court; time for filing action; plaintiffs; defendant; procedure.
✓ current as of July 2026 Cite as: Mich. Comp. Laws § 600.4545 (2026)
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REVISED JUDICATURE ACT OF 1961
Act 236 of 1961
600.4545 Election fraud or error; circuit court; time for filing action; plaintiffs; defendant; procedure.
Sec. 4545.
(1) An action may be brought in the circuit court of a county of this state if it appears that material fraud or error has been committed in an election to decide a constitutional amendment, question, or proposition to the electors of this state or a county, township, or municipality of this state. This section does not apply to, and does not authorize, an action relating to an election for public office.
(2) An action under subsection (1) must be brought not later than 30 days after the election by the attorney general or the prosecuting attorney of the proper county on the attorney general's or prosecuting attorney's own relation, on the relation of any citizen of the county without leave of the court, or by any citizen of the county by special leave of the court or a judge of the court. The action must be brought against the municipality in which the fraud or error is alleged to have been committed.
(3) After an action under subsection (1) is brought, the procedure must conform as near as may be to that provided by law for actions for quo warranto.
History: 1961, Act 236, Eff. Jan. 1, 1963 ;-- Am. 2023, Act 256, Eff. Feb. 13, 2024
Notes of Decisions
Cited in 23
cases (3 in the last 5 years), 1964–2024 · leading case: Salem Springs, LLC v. Salem Township
Salem Springs, LLC v. Salem Township (2015)
“In this case, brought in the nature of a quo warranto action under MCL 600.4545, plaintiff, Salem Springs, LLC, challenged the results of a voter referendum pertaining to a zoning amendment in Salem Township.”
Hanlin v. Saugatuck Township (2013)
“The parties filed cross-motions for summary disposition, with plaintiffs arguing that those irregularities, as well as others, supported an action for quo warranto on the basis of “fraud or gross error” pursuant to MCL 600.4545 and on the basis of “fraudulent or illegal voting,…”
Bloomfield Charter Township v. Oakland County Clerk (2002)
“Several motions for summary disposition, and much briefing, by the parties led to the circuit court’s ultimate resolution of the issues as follows: (1) The circuit court declined to grant the township equitable relief in the form of an injunction preventing the upcoming…”
Barrow v. Detroit Mayor (2010)
“The county appellees countered that because propositions B and S were on the same ballot as the mayor’s race, the statutory subsection of MCL 600.4545 dealing with material fraud or error applied and appellant’s application was time-barred.”
Risk v. Lincoln Charter Township Board of Trustees (2008)
“1 In actuality, this is both a traditional quo warranto action and an action in the nature of quo warranto brought pursuant to MCL 600.4545. It is a traditional quo warranto action to the extent that it was brought to try title to the offices of Lincoln Charter Township park…”
Wills v. Iron County Board of Canvassers (1990)
“Plaintiff also requested the court to grant him special leave to proceed with a quo warranto action pursuant to MCL 600.4545; MSA 27A.4545, which provides: (1) An action may be brought in the circuit court of any county of this state whenever it appears that material fraud or…”
Penn School District No. 7 v. Lewis Cass Intermediate School District Board of Education (1968)
“Following the election the individual plaintiffs sought and were granted leave to proceed in the nature of quo warranto (CLS 1961, § 600.4545 [Stat Ann 1962 Rev § 27A.4545]).”
Smith v. Scio Township (1988)
“46(27), while making no mention of decreases, the Legislature implicitly precluded electors from limiting the board's taxing authority to an amount less than five mills.”
Township of Owosso v. City of Owosso (1970)
“3 Although this cause was not specifically brought under MCLA § 600.4545 (Stat Ann 1962 Rev § 27A.”
Township of Almont v. County of Lapeer (2018)
“The trial court held that MCL 600.4545 governed challenges to alleged errors in elections and that a complaint under the statute must be filed within 30 days of the election.”
St. Joseph Township v. City of St. Joseph (1964)
“” Currently, see CLS 1961, § 600.4545 (Stat Ann 1962 Rev § 27A-.4545).”
DARTLAND EX REL. De MOTTS v. Hancock Schools (1970)
“(1) An action may be brought in the circuit court of any county of this state whenever it appears that material fraud or error has been committed at any election in such county at which there has been submitted any constitutional amendment, question, or proposition to the…”
— Mich. Comp. Laws § 600.4545(1) — 8 cases
Hanlin v. Saugatuck Township (2013)
“The parties filed cross-motions for summary disposition, with plaintiffs arguing that those irregularities, as well as others, supported an action for quo warranto on the basis of “fraud or gross error” pursuant to MCL 600.4545 and on the basis of “fraudulent or illegal voting,…”
Salem Springs, LLC v. Salem Township (2015)
“In this case, brought in the nature of a quo warranto action under MCL 600.4545, plaintiff, Salem Springs, LLC, challenged the results of a voter referendum pertaining to a zoning amendment in Salem Township.”
Risk v. Lincoln Charter Township Board of Trustees (2008)
“1 In actuality, this is both a traditional quo warranto action and an action in the nature of quo warranto brought pursuant to MCL 600.4545. It is a traditional quo warranto action to the extent that it was brought to try title to the offices of Lincoln Charter Township park…”
— Mich. Comp. Laws § 600.4545(2) — 5 cases
Salem Springs, LLC v. Salem Township (2015)
“In this case, brought in the nature of a quo warranto action under MCL 600.4545, plaintiff, Salem Springs, LLC, challenged the results of a voter referendum pertaining to a zoning amendment in Salem Township.”
Wills v. Iron County Board of Canvassers (1990)
“Plaintiff also requested the court to grant him special leave to proceed with a quo warranto action pursuant to MCL 600.4545; MSA 27A.4545, which provides: (1) An action may be brought in the circuit court of any county of this state whenever it appears that material fraud or…”
Risk v. Lincoln Charter Township Board of Trustees (2008)
“1 In actuality, this is both a traditional quo warranto action and an action in the nature of quo warranto brought pursuant to MCL 600.4545. It is a traditional quo warranto action to the extent that it was brought to try title to the offices of Lincoln Charter Township park…”
Township of Almont v. County of Lapeer (2018)
“The trial court held that MCL 600.4545 governed challenges to alleged errors in elections and that a complaint under the statute must be filed within 30 days of the election.”
— Mich. Comp. Laws § 600.4545(3) — 2 cases
Hanlin v. Saugatuck Township (2013)
“The parties filed cross-motions for summary disposition, with plaintiffs arguing that those irregularities, as well as others, supported an action for quo warranto on the basis of “fraud or gross error” pursuant to MCL 600.4545 and on the basis of “fraudulent or illegal voting,…”
Risk v. Lincoln Charter Township Board of Trustees (2008)
“1 In actuality, this is both a traditional quo warranto action and an action in the nature of quo warranto brought pursuant to MCL 600.4545. It is a traditional quo warranto action to the extent that it was brought to try title to the offices of Lincoln Charter Township park…”
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