The Michigan Supreme Court has denied leave to appeal in Teddy 23 LLC v Michigan Film Office, No. 153420-1, following mini-oral argument on the question of whether the Court of Claims has subject-matter jurisdiction over an appeal from a decision made by the Michigan Film Office.
After the Michigan Film Office denied Teddy 23’s request for a postproduction certificate of completion, Teddy 23 filed an action in the Court of Claims against the Michigan Film Office and the Department of Treasury. The Court of Claims dismissed the case for lack of subject-matter jurisdiction. The Court of Appeals affirmed, holding that the Revenue Act confers subject-matter jurisdiction on the Court of Claims for decisions issued by the Department of Treasury, but not the Michigan Film Office.
Justice Young disagreed with the Supreme Court’s denial of leave to appeal. As set out in his dissenting opinion, Young believed that MCL 600.6419(1)(a) gives the Court of Claims exclusive jurisdiction over Teddy 23’s claim. That statute provides, in relevant part, that the Court of Claims has exclusive jurisdiction to hear “any demand for monetary, equitable, or declaratory relief . . . against the state or any of its departments or officers.”
Justice Young then grappled with the carve-out in MCL 600.6419(5), whereby the circuit court retains exclusive jurisdiction over appeals from the district court and administrative agencies when some other law grants such exclusive jurisdiction. The other law at play here, MCL 600.631, gives circuit courts jurisdiction over appeals from any decision of any state agency authorized to promulgate rules “from which an appeal or other judicial review has not otherwise been provided for by law.” Justice Young reasoned that because that statute has no language to suggest the circuit court’s jurisdiction is exclusive, MCL 600.6419(5) should not apply. Moreover, he argued, MCL 600.6419(1)(a) implicates the “otherwise been provided for by law” language of MCL 600.631, as the former grants to the Court of Claims judicial review of claims like Teddy 23’s.