City of Center Line v. 37th District Judges

Citations: 271 N.W.2d 526; 403 Mich. 595; 1978 Mich. LEXIS 362Docket: 59520, (Calendar No. 7)

Court: Michigan Supreme Court; November 20, 1978; Michigan; State Supreme Court

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The City of Center Line challenged the arrangement of the 37th judicial district, arguing that at least one judge must operate full-time within its facilities due to constitutional and statutory requirements. The 1963 Michigan Constitution mandated the establishment of limited jurisdiction courts, with the Legislature responding by enacting the district court act, which created the 37th district, including Warren and Center Line. Center Line opted out of the district court system, but because it did not constitute over 50% of the district's population, this action was ineffective. Subsequently, the 37th district began operations in 1969, with most judges operating in Warren's newly constructed judicial building by 1975, leading to concerns from Center Line about losing court operations entirely. Center Line filed a complaint seeking declaratory and injunctive relief, claiming statutes required cases to be heard where they arose. The circuit court ruled that only small claims and ordinance violations needed to be heard in Center Line, while the Court of Appeals later affirmed that certain arraignments and preliminary examinations related to Center Line offenses must also occur within the city. Additionally, Center Line contended that the statutory provision (RJA. 9928) infringed on its equal protection and due process rights by preventing it from retaining its municipal court, unlike other cities in similar positions.

A due process violation is claimed regarding the Legislature's delegation of authority to Warren to decide the effectiveness of 1968 PA 154 in Center Line. The Court of Appeals noted that declaring MCLA 600.9928 unconstitutional would not provide the relief sought by the plaintiff, as the municipal court in Center Line was abolished by MCLA 600.9921. Voiding MCLA 600.9928 would not restore the municipal court or assist in that regard. The court determined that even if MCLA 600.9928 were found unconstitutional, it could be severed from 1968 PA 154, and this outcome would not benefit the city.

The controversy centers on RJA 8251(3), which mandates that in third-class districts, courts must sit in cities with populations over 3,250 and townships over 12,000, unless agreed otherwise by the governing body and the court. Center Line interprets "sit" to mean having one of the four judges physically located there, which was the case from 1969 to 1975. This interpretation would necessitate travel for Warren parties, witnesses, and attorneys to Center Line for hearings. The court declined to interpret the statute to create full-time judge locations where none currently exist, stating that the statute only requires some judicial business to be conducted in Center Line, not necessarily a full-time presence.

Furthermore, the statute mandates that the small claims division of the 37th judicial district must convene in Center Line at least once every 30 days. Civil cases are governed by RJA 8312(5), which stipulates that venue must be in the district where the action arose or where the defendant resides. The city acknowledges that civil cases are not required to be tried in a specific location but argues for the convenience of litigating in Center Line. Following the changes in 1974 PA 319, RJA 8312(5) now aligns civil actions with judicial district provisions, affirming that a judicial district is a proper venue for cases originating within it. Center Line contends that all criminal violations occurring there should also be heard in that location.

Venue for criminal actions in third-class districts is governed by RJA. 8312(3) and 8312(4)(a). Violations of state law and local ordinances are generally tried in the political subdivision where the violation occurred. However, if a violation occurs in a subdivision where the court does not sit, it can be tried in any subdivision within the same district where the court is required to sit. Special provisions apply for state criminal violations: if an offense occurs on the boundary of multiple jurisdictions or within one mile, venue is proper in any of those jurisdictions. Center Line ordinance violations must be heard in Center Line; however, since it is within one mile of Warren, state criminal violations can also be heard in Warren under the exception clause.

The Court of Appeals clarified that this exception applies only to state criminal violations cognizable by the district court, specifically misdemeanors punishable by up to one year in prison. Other violations, such as felonies, must be heard in Center Line. The later enacted 1970 PA 213 introduces additional venue provisions for offenses cognizable by an examining magistrate, stating that if an offense occurs near jurisdictional boundaries, venue is proper in any concerned subdivision. This later statute takes precedence over RJA. 8312(3).

The circuit court correctly determined that certain cases must be heard in Center Line, but it is open to requests for administrative authority if the city can show that judicial resources could be better utilized in the 37th judicial district. The circuit court's judgment was affirmed by the majority, while some justices concurred in part and dissented in part, emphasizing that the legislative intent was for the court to handle all judicial business in cities with populations over 3,250 and that venue provisions do not grant judges the power to limit the scope of cases. The majority's view is that while the entire judicial district is a proper forum, it does not prohibit cases from being initiated in other locations within the district.

Judges of the court do not have the authority to choose the location for hearings beyond statutory designations and must hold court in specified places within the district. The 37th district includes Warren and Center Line, and is classified as a third-class district with four judges. Statutory provisions require the court to sit in cities with populations of 3,250 or more and townships with populations of 12,000 or more, while allowing judges to decide additional locations. However, judges cannot refuse to hold court in places designated by statute. This ensures defendants are not compelled to respond to cases in unsuitable venues and aims to provide convenience for litigants and attorneys.

The majority opinion suggests that small claims must be heard in Center Line once every 30 days but does not clarify if all small claims can be heard in Warren. The statute allows small claims actions in the district where the cause arose or where the defendant resides, implying judges may require all judicial matters to be conducted in Warren, except for Center Line ordinance violations.

Regarding criminal actions, the majority states that violations of local ordinances must be heard in the jurisdiction where the violation occurred, specifically Center Line. However, for state law violations happening in Center Line, venue does not have to be limited to that city, as a 1970 amendment allows for venue in any adjacent political subdivision if the violation occurs near the boundary.

The amended provision addresses offenses near the boundaries of political subdivisions where venue determination may be challenging, facilitating prosecution by preventing offenders from contesting venue. The majority opinion interprets that the Legislature allowed district judges in the 37th district to centralize state law violations but did not extend this power beyond a mile from a designated subdivision's boundary. The district court act, enacted under the Michigan Constitution, mandated the establishment of limited jurisdiction courts within five years, while existing municipal courts remained unchanged until legally abolished. The act reflects a legislative compromise, as cities above a certain population were designated as district court locations, ensuring courts would operate in a standard capacity rather than selectively. Legislative intent did not support limiting judicial business in Center Line, where the court is mandated to conduct all appropriate judicial activities. An order is suggested to affirm that the 37th district must operate in Center Line for all relevant judicial business without restriction by the judges, supported by concurring opinions from KAVANAGH, C.J., WILLIAMS, and LEVIN, JJ.