Cameron v. Monroe County Probate Court

Citations: 543 N.W.2d 71; 214 Mich. App. 681Docket: Docket 159808

Court: Michigan Court of Appeals; December 28, 1995; Michigan; State Appellate Court

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In the case of Cameron v. Monroe County Probate Court, the Michigan Court of Appeals addressed an appeal from the Monroe County Probate Court concerning a summary disposition order related to a judgment against it. The underlying lawsuit, initiated by Cindy and Lawrence Cameron, involved claims of marital-status discrimination under the Civil Rights Act and loss of consortium against the Probate Court and its judge, James Seitz. After mediation, a judgment of $25,000 was entered against the Probate Court.

The Probate Court then filed a third-party complaint against Monroe County, asserting that it was responsible for any judgment against the Probate Court. However, Judge Colombo ruled that Monroe County was not liable for the judgment, referencing prior case law that established that while Monroe County funds the Probate Court, it is not legally obligated to pay judgments against it. The ruling emphasized that employees of the Probate Court are considered employees of the state’s judicial system, not the county, reaffirming that the state bears responsibility for such judgments, not the county. The Court of Appeals affirmed Judge Colombo's decision.

Cindy Cameron is determined to be an employee of the Monroe County Probate Court rather than Monroe County, based on legal precedent and an Attorney General opinion from 1979 that identifies the probate court as the public employer for its employees regarding collective bargaining. The Attorney General argues otherwise, citing cases such as Nezdropa v Wayne Co and Kain v Michigan, but these do not substantiate his position. Nezdropa pertains to worker's compensation, while Kain clarifies that the city was not the employer of the district court clerk but rather liable for worker’s compensation as the district control unit. Additionally, the Attorney General's reliance on MCL 600.9101 et seq. is misplaced, as it only designates the State Judicial Council as the employer for state-paid judicial branch employees, which does not apply to Cameron since it is agreed she was not state-paid. The statutes referenced do not clarify the employment status of other courts' employees.

The crux of the matter is not the identity of Cameron's employer but determining which entity is legally responsible for any monetary judgment against the Monroe County Probate Court. The courts, as part of state government, imply that the state would be liable for such judgments, as supported by case law indicating that claims against the state and its instrumentalities belong in the Court of Claims. There is no statutory obligation for the district control unit to pay any judgment, thus reinforcing that the state would bear primary responsibility for any potential judgment against the district court or its judge acting in an official capacity.

The trial court's decision to transfer the plaintiff's case to the Court of Claims was upheld, with the appellant probate court's arguments deemed insufficient. The court clarified that a statement in Kell, asserting that "the state would be primarily responsible for a judgment," was essential to the ruling and not mere dicta. Unlike district courts, probate courts lack a statutory obligation for operational costs, as district control units are specifically defined and funded by local governments under MCL 600.8104. In contrast, while probate courts operate on local funding, the Legislature has not placed the burden of paying money judgments against them on counties. Legal precedent established that local funding units are only obligated to provide resources necessary for statutory functions; since paying money judgments is not a statutory function of probate courts, counties are not liable. Consequently, it was concluded that the state bears primary responsibility for any judgments against the Monroe County Probate Court. Additionally, the court found that common-law indemnification was not applicable, as neither the county nor the probate court had engaged in wrongdoing. The ruling was affirmed.