Narrative Opinion Summary
In this case, the plaintiff, a veterinarian, challenged the Washtenaw Circuit Court's decision, which granted summary disposition in favor of Bobson Construction Company. The lower court had ruled that the claims were barred by a four-year statute of limitations under the Uniform Commercial Code (UCC), considering the contract as primarily for the sale of goods. The plaintiff argued that the contract was for services, invoking the six-year statute of limitations under Michigan law. The Court of Appeals reviewed the case de novo, considering the economic loss doctrine and employing the predominant factor test. The appellate court determined that the contract predominantly involved services related to roof installation, rather than the sale of goods. Consequently, the six-year statute of limitations under M.C.L. 600.5807(8) was applicable, rendering the plaintiff's claims timely. The appellate court reversed the trial court's decision and remanded the case for further proceedings, concluding that the trial court erroneously applied the UCC statute of limitations to the claims.
Legal Issues Addressed
Application of Uniform Commercial Code Statute of Limitationssubscribe to see similar legal issues
Application: The contract was deemed primarily for services, thus the UCC's four-year statute of limitations did not apply.
Reasoning: The contract in question is primarily for services related to the installation of a new roof, rather than for the sale of goods, meaning it is not governed by the Uniform Commercial Code (UCC) statute of limitations.
Economic Loss Doctrine and Predominant Factor Testsubscribe to see similar legal issues
Application: The Court of Appeals used the economic loss doctrine and the predominant factor test to determine that the transaction was for services, leading to the application of Michigan's six-year statute of limitations.
Reasoning: The court employed a test from Bonebrake v. Cox to determine whether the predominant factor of the contract was the provision of services or the sale of goods.
Statute of Limitations for Breach of Contractsubscribe to see similar legal issues
Application: The six-year statute of limitations under M.C.L. 600.5807(8) was applied, as the contract was for services and the plaintiff’s claim was filed within this period.
Reasoning: Here, the applicable statute of limitations for breach of contract is six years, as per M.C.L. 600.5807(8), and the plaintiff's claim was filed within this period, making it timely.