Michigan Compiled Laws
Mich. Comp. Laws § 600.6023a (2026)
Property held jointly by husband and wife; exemption under judgment entered against 1 spouse.
✓ current as of July 2026
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REVISED JUDICATURE ACT OF 1961
Act 236 of 1961
600.6023a Property held jointly by husband and wife; exemption under judgment entered against 1 spouse.
Sec. 6023a.
Property described in section 1 of 1927 PA 212, MCL 557.151, or real property, held jointly by a husband and wife as a tenancy by the entirety is exempt from execution under a judgment entered against only 1 spouse.
History: Add. 2004, Act 575, Imd. Eff. Jan. 3, 2005
Notes of Decisions
Cited in 12
cases (1 in the last 5 years), 1970–2025 · leading case: Estes v. Titus, 751 N.W.2d 493 (Mich. 2008).
Estes v. Titus, 751 N.W.2d 493 (Mich. 2008). “18 MCL 600.6023a. 7 comprehend how disposing of property that a creditor cannot reach could “defraud” that creditor.”
Zavradinos v. JTRB, INC., 753 N.W.2d 60 (Mich. 2008). “Hence, defendants' accounts were not protected by MCL 600.6023a. CORRIGAN, J., dissents and states as follows: I dissent from the order denying leave to appeal.”
Nino v. Moyer, 437 B.R. 230 (W.D. Mich. 2009). “5451(l)(o) is a bankruptcy-specific exemption whereas section 600.6023a is a general exemption from execution of judgment.”
In Re Pontius, 421 B.R. 814 (Bankr. W.D. Mich. 2009). “Unlike the situation in Basch , the Debtor is unmarried and cannot claim § 600.6023a, a general exemption, which applies only to entireties property.”
Olson v. Parker (In Re Parker), 395 B.R. 12 (Bankr. W.D. Mich. 2008). “Mich. Comp. Laws 600.6023a. It stands to equal reason, though, that property held by the entire-ties may be subject to execution if the creditor’s claim is against both spouses.”
In Re Guzior, 347 B.R. 237 (Bankr. E.D. Mich. 2006). “5451 and § 600.6023a. These statutes were immediately effective on January 3, 2005 and address exemption of an entireties property interest.”
Lewiston v. Kohut (In re Lewiston), 539 B.R. 154 (E.D. Mich. 2015). “§ 600.6023a; Budwit, 339 Mich, at 278 , 63 N.”
Shapiro v. Sassak, 426 B.R. 680 (E.D. Mich. 2010). “) Appellant points out that the appearance in section 5451 of language that is virtually, identical to a parallel provision in MCL 600.6023a (MCL 600.5451(l)(o) and MCL 600.”
Davis v. Sequin, 176 N.W.2d 707 (Mich. Ct. App. 1970). “On August 3, 1964, a writ of execution was issued from the Muskegon county circuit court, and pursuant thereto, levy was made on plaintiff’s 1955 model automobile which he claimed was exempt from levy by virtue of MCLA § 600.6023a(5) (Stat Ann 1970 Cum Supp § 27A.”
Kimberly Knapp v. Vulpina LLC (Mich. Ct. App. 2019). “It is also undisputed that after the trial court entered the consent judgment of divorce, Knapp and Dzierzawski owned the marital property as tenants in common.”
Caldwell Co. v. Yousif (E.D. Mich. 2025). “§ 600.6023a; Mich. Comp. L. § 566.31(b)(iii) (Property of a debtor under MUVTA does not include “an interest in property held in tenancy by the entireties to the extent it is not subject to process by a creditor that holds a claim against only 1 tenant.”
Jan Kay Estes v. Jeff Edward Titus (Mich. 2008). “18 MCL 600.6023a. 7 comprehend how disposing of property that a creditor cannot reach could “defraud” that creditor.”
— Mich. Comp. Laws § 600.6023a(5) — 1 case
Davis v. Sequin, 176 N.W.2d 707 (Mich. Ct. App. 1970). “On August 3, 1964, a writ of execution was issued from the Muskegon county circuit court, and pursuant thereto, levy was made on plaintiff’s 1955 model automobile which he claimed was exempt from levy by virtue of MCLA § 600.6023a(5) (Stat Ann 1970 Cum Supp § 27A.”
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