The Michigan Court of Appeals in New Products Corp. v. Harbor Shores BHBT Land Development, LLC, No 317309, held that the Michigan Quiet Title Statute, MCL 600.2932, is constitutional and permits the trial court to determine whether the action is in equity or in law to decide a party's right to a jury trial.
In 2011 New Products sued Harbor Shores Development ("Harbor Shores") and others alleging that it was the rightful owner of property at issue and that Harbor Shores had wrongfully constructed and maintained a golf course on its land. New Products filed actions for trespass, a claim historically at law, and other equitable claims to quiet title. New Products demanded the right to have a jury decide all the issues.
Harbor Shores argued that under MCL 600.2932 the equitable claims filed by New Products, including injunctive relief, declaratory relief, and claims for quiet title are claims at equity and must be deiced by the court; however the claims for trespass were at law and could be decided by a jury. New Products maintained that under the Michigan Constitution, it had a right to a trial by jury on all issues.
The Court of Appeals, after a detailed analysis of the Michigan Constitution and MCL 600.2932, held that the legislature did not intend to remove the right to a jury or the right to a trial by the court under the statute. Rather, the Court held that actions brought under MCL 600.2932 which were historically brought in courts of equity remain the province of the court, while claims brought under the statute which were historically at law, have a constitutional right to a jury trial.
The Court therefore upheld the trial court's determination that the equitable claims shall be tried by the court, while the action for trespass, a claim at law, may be decided by a jury.
