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

Mich. Comp. Laws § 600.6452 (2026)

Court of claims; filing of claim; time; limitation of actions; right of attorney general to petition for administration of estate or appoint guardian of minor or disabled; applicability to claims for compensation under the wrongful imprisonment compensation act.

✓ current as of July 2026
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REVISED JUDICATURE ACT OF 1961


Act 236 of 1961


600.6452 Court of claims; filing of claim; time; limitation of actions; right of attorney general to petition for administration of estate or appoint guardian of minor or disabled; applicability to claims for compensation under the wrongful imprisonment compensation act.

Sec. 6452.

    (1) Every claim against this state, cognizable by the court of claims, is forever barred unless the claim is filed with the clerk of the court or an action is commenced on the claim in federal court as authorized in section 6440, within 3 years after the claim first accrues.

    (2) Except as modified by this section, chapter 58, relative to the limitation of actions, also applies to the limitation under this section.

    (3) The attorney general has the same right as a creditor under the statutes of this state to petition for the appointment of a personal representative of the estate of a deceased person.

    (4) The attorney general has the same right as a superintendent of the poor under the statutes of this state to petition for the appointment of a guardian of the estate of a minor or any other individual under a disability.

    (5) This section does not apply to a claim for compensation under the wrongful imprisonment compensation act, 2016 PA 343, MCL 691.1751 to 691.1757.

    

    

History: 1961, Act 236, Eff. Jan. 1, 1963 ;-- Am. 2020, Act 44, Imd. Eff. Mar. 3, 2020

Compiler's Notes:

    Enacting section 1 of Act 44 of 2020 provides:

    "Enacting section 1. Section 6452 of the revised judicature act of 1961, 1961 PA 236, MCL 600.6452, as amended by this amendatory act, applies retroactively to March 29, 2017."

Notes of Decisions
Cited in 41 cases (11 in the last 5 years), 1971–2026 · leading case: Melissa Mays v. Governor Rick Snyder, 916 N.W.2d 227 (Mich. Ct. App. 2018).
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Melissa Mays v. Governor Rick Snyder, 916 N.W.2d 227 (Mich. Ct. App. 2018). · cites it 15× “In pertinent part, MCL 600.6452, which deals with the "limitation of actions," provides that "the provisions of RJA chapter 58, relative to the limitation of actions, shall also be applicable to the limitation prescribed in this section .”
Wayne Cnty. Chief Exec. v. Governor, 583 N.W.2d 512 (Mich. Ct. App. 1998). · cites it 5× “308(1)(3) or the three-year period of limitation set forth at MCL 600.6452(1); MSA 27A.6452(1) is applicable to a suit brought pursuant to the second sentence of § 29 of the Headlee Amendment.”
Gleason v. Dep't of Transp., 662 N.W.2d 822 (Mich. Ct. App. 2003). “” MCL 600.6452(1). A statute of limitations is a procedural, not substantive, rule.”
Spiek v. Dep't of Transp., 572 N.W.2d 201 (Mich. 1998). “5 MCL 600.6452; MSA 27A6452. 6 MCL 600.5813; MSA 27A.”
Brown v. Dep't of Military Affairs, 191 N.W.2d 347 (Mich. 1971). · cites it 6× “6431); MCLA § 600.6452 (Stat Ann 1962 Rev § 27A.”
Bay Mills Indian Cmty. v. State, 626 N.W.2d 169 (Mich. Ct. App. 2001). “Subsection *751 6452(1) of the Court of Claims Act, MCL 600.6452(1); MSA 27A.6452(1), states that a claim against the state brought in the Court of Claims expires unless it is filed three years after it accrues.”
Lowery v. Dep't of Corr., 380 N.W.2d 99 (Mich. Ct. App. 1985). “In contrast, the lower court held that the three-year period of limitation found in the Court of Claims Act applied, MCL 600.6452(1); MSA 27A.6452(1), and that by virtue of his incarceration plaintiff was entitled under MCL 600.”
Smith v. Dep't of Treasury, 414 N.W.2d 374 (Mich. Ct. App. 1987). · cites it 2× “Plaintiffs contend that the appropriate statute of limitation is contained in the RJA Court of Claims Act, MCL 600.6452(1); MSA 27A.6452(1), which establishes a three-year limitation period for claims against the state, commencing when the claim first accrues.”
Oak Constr. Co. v. Dep't of State Highways, 190 N.W.2d 296 (Mich. Ct. App. 1971). · cites it 2× “The other is the three-year statute of limitations found in MCLA § 600.6452(1) (Stat Ann 1962 Kev § 27A.”
Lawson v. Edwardsburg Pub. Sch., 751 F. Supp. 1257 (W.D. Mich. 1990). “§§ 600.6452(1), 691.1411(3) (West 1987). Having determined that a three-year limitations period is applicable to the plaintiff Gregory Lawson’s cause of action, the Court holds that any claims concerning Cases C-1449-85 and C-1578-85 are barred.”
William C Reichenbach Co. v. State, 288 N.W.2d 622 (Mich. Ct. App. 1979). “The defendant argues that a one-year statute of limitations is more appropriate relying upon the language found in the payment-bond statute. In pertinent part that statute reads: *329 "An action instituted on the payment bond shall be brought only in the appropriate court in the…”
Adr Consultants LLC v. Michigan Land Bank Fast Track Auth., 932 N.W.2d 226 (Mich. Ct. App. 2019). · cites it 2× “With that said, the purpose of the one-year requirement is to provide notice of a claim, while the longer three-year statute of limitations under MCL 600.6452(1) is to make the claim specific.”
Show all 41 citing cases →
— Mich. Comp. Laws § 600.6452(1) — 31 cases
Wayne Cnty. Chief Exec. v. Governor, 583 N.W.2d 512 (Mich. Ct. App. 1998). “308(1)(3) or the three-year period of limitation set forth at MCL 600.6452(1); MSA 27A.6452(1) is applicable to a suit brought pursuant to the second sentence of § 29 of the Headlee Amendment.”
Melissa Mays v. Governor Rick Snyder, 916 N.W.2d 227 (Mich. Ct. App. 2018). “In pertinent part, MCL 600.6452, which deals with the "limitation of actions," provides that "the provisions of RJA chapter 58, relative to the limitation of actions, shall also be applicable to the limitation prescribed in this section .”
Gleason v. Dep't of Transp., 662 N.W.2d 822 (Mich. Ct. App. 2003). “” MCL 600.6452(1). A statute of limitations is a procedural, not substantive, rule.”
Brown v. Dep't of Military Affairs, 191 N.W.2d 347 (Mich. 1971). “6431); MCLA § 600.6452 (Stat Ann 1962 Rev § 27A.”
Bay Mills Indian Cmty. v. State, 626 N.W.2d 169 (Mich. Ct. App. 2001). “Subsection *751 6452(1) of the Court of Claims Act, MCL 600.6452(1); MSA 27A.6452(1), states that a claim against the state brought in the Court of Claims expires unless it is filed three years after it accrues.”
— Mich. Comp. Laws § 600.6452(2) — 11 cases
Melissa Mays v. Governor Rick Snyder, 916 N.W.2d 227 (Mich. Ct. App. 2018). “In pertinent part, MCL 600.6452, which deals with the "limitation of actions," provides that "the provisions of RJA chapter 58, relative to the limitation of actions, shall also be applicable to the limitation prescribed in this section .”
Smith v. Dep't of Treasury, 414 N.W.2d 374 (Mich. Ct. App. 1987). “Plaintiffs contend that the appropriate statute of limitation is contained in the RJA Court of Claims Act, MCL 600.6452(1); MSA 27A.6452(1), which establishes a three-year limitation period for claims against the state, commencing when the claim first accrues.”
Melissa Mays v. Governor Rick Snyder (Mich. 2020).
Melissa Mays v. Governor Rick Snyder (Mich. 2020).
Bonner v. Moore, 216 N.W.2d 458 (Mich. Ct. App. 1974).
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