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A Better Partnership
November 20, 2014

MSC interprets the definition of locality under Michigan’s Worker’s Disability Compensation Act

In Younkin v. Zimmer, No. 149355, the Michigan Supreme Court reversed the Court of Appeals and held that a trial court should not have issued a writ of mandamus ordering the Michigan Administrative Hearing System and Michigan Department of Licensing and Regulatory Affairs (LARA) to hold a hearing within the same county where a worker’s injury was located. The Supreme Court then expanded the meaning of “locality” under the Worker’s Disability Compensation Act and interpreted the term as a district or definite region.
In this case, Younkin was injured while working at a GM facility in Genesee County and subsequently filed a claim for workers’ compensation benefits. The defendant directors of the Michigan Administrative Hearing System and LARA announced that it was reorganizing its workers compensation hearing sites. Under the new system, defendants divided the state into eleven hearing districts where workers’ compensation claims would be assigned; depending on which district the injury occurred. As a consequence, the Genesee County site that previously heard workers’ compensation claims closed. Younkin’s claims were transferred to the Dimondale district office, which is located in Eaton County seventy miles away. 
According to MCL 418.851, a workers’ compensation hearing must be held at the locality where the injury occurred. Younkin sought a writ of mandamus compelling defendants to maintain its Genesee County site, thereby claiming that hearings must be in the same county in which an employee’s injury occurred.  On the other hand, defendants interpreted the definition of locality as a “district” or “a definite region” rather than the city or county where the injury occurred. The trial court granted the writ and the Court of Appeals affirmed.
The Michigan Supreme Court disagreed with the lower courts and held that the defendant directors’ interpretation of locality was reasonable because it did not conflict with the legislature’s intent. The Court explained that the legislature did not specifically state that a workers’ compensation hearing must be held in the same city or county where the injury occurred. The Court then concluded that the locality where Younkin’s injury occurred was Dimondale because Genesee County falls within the department’s newly developed Dimondale district. Therefore, the Michigan Supreme Court reversed and remanded the case back to the trial court to deny Younkin relief for mandamus.

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