Michigan Compiled Laws

Mich. Comp. Laws § 750.170 (2026)

Disturbance of lawful meetings.

✓ current as of July 2026
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THE MICHIGAN PENAL CODE


Act 328 of 1931


750.170 Disturbance of lawful meetings.

Sec. 170.

    Disturbance of lawful meetings—Any person who shall make or excite any disturbance or contention in any tavern, store or grocery, manufacturing establishment or any other business place or in any street, lane, alley, highway, public building, grounds or park, or at any election or other public meeting where citizens are peaceably and lawfully assembled, shall be guilty of a misdemeanor.

History: 1931, Act 328, Eff. Sept. 18, 1931 ;-- CL 1948, 750.170

FormerLaw Notes:

    See section 20 of Ch. 158 of R.S. 1846, being CL 1857, § 5875; CL 1871, § 7710; How., § 9296; CL 1897, § 11709; CL 1915, § 15483; CL 1929, § 16835; Act 191 of 1887; and Act 211 of 1909.

Notes of Decisions
Cited in 52 cases (28 in the last 5 years), 1967–2026 · leading case: People v. Vandenberg, 859 N.W.2d 229 (Mich. Ct. App. 2014).
People v. Vandenberg, 859 N.W.2d 229 (Mich. Ct. App. 2014). · cites it 17× “81d(l), and making or exciting any disturbance or contention, MCL 750.170. Because the phrase “excite any.”
Thomas Leonard v. Stephen Robinson, in His Individual Capacity, 477 F.3d 347 (6th Cir. 2007). · cites it 2× “The undisputed facts (undisputed because the record contains a video of the incident) show that Robinson observed Leonard at a “public meeting where citizens were peaceably and lawfully assembled,” Mich. Comp. Laws § 750.170 , yelling, swearing and answering requests with the…”
People v. Purifoy, 191 N.W.2d 63 (Mich. Ct. App. 1971). · cites it 8× “MCLA § 750.170 (Stat Ann 1962 Rev § 28.367).”
People v. Jones, 829 N.W.2d 350 (Mich. Ct. App. 2013). “1 See Hornsby, 251 Mich App at 468 ; MCL 750.170 (prohibiting a disturbance of the peace in a store or business place); MCL 750.”
People v. Mash, 206 N.W.2d 767 (Mich. Ct. App. 1973). · cites it 3× “Defendant Roy Mash appeals on leave granted from a judgment of the Washtenaw County Circuit Court, which affirmed defendant’s district court conviction for making a disturbance in a public building, contrary to MCLA 750.170; MSA 28.367. Defendant was convicted for his…”
Lamonte Jackson-Gibson v. Reginald Beasley, 118 F.4th 848 (6th Cir. 2024). “See Mich. Comp. Laws §§ 750.170 ; 750.479(1)(b).”
People v. Weinberg, 149 N.W.2d 248 (Mich. Ct. App. 1967). · cites it 2× “On October 24, 1963, the defendants were charged with exciting and making a disturbance or contention in a business place in violation of OL 1948, § 750.170 (Stat Ann 1962 Rev § 28.367), and with failure to leave a business place when ordered by a duly authorized agent, in…”
People of Michigan v. Bradly Thomas Peterson (Mich. Ct. App. 2020). · cites it 23× “170 was unconstitutional as applied to him.”
Gary Anderson v. Alexis Holmes (6th Cir. 2022). · cites it 9× “The officers first contend that they had probable cause to believe that Anderson had violated Mich. Comp. Laws § 750.170 , which makes it a misdemeanor to “make or excite” a “disturbance” in a “public building.”
People of Michigan v. Tina Marie Carroll (Mich. Ct. App. 2023). · cites it 9× “81d(1), and one count of disturbing the peace, MCL 750.170, for which she was sentenced to three days in jail (time served) and 24 months’ probation.”
People of Michigan v. Autry Keith Bedwell (Mich. Ct. App. 2019). · cites it 7× “The circuit court sentenced defendant to three concurrent terms of two years’ probation with a deferred sentence of 365 days in jail for the R&O convictions and two days in jail for the disturbing the peace conviction, with credit for two days served.”
People of Michigan v. Joaquin Nathaniel Edwards (Mich. Ct. App. 2026). · cites it 7× “2 As discussed later, the district court indicated that it bound defendant over on the charges of either disturbing the peace, MCL 750.170, or a violation of Jackson Ordinance, § 17-86, in addition to the resisting charge.”
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