Narrative Opinion Summary
The Supreme Court of Michigan reviewed whether the City of Saline's decision to acquire 160 acres of property was subject to a referendum. The city council had previously authorized action towards annexation and exercised a purchase option for the property, which led to the plaintiff seeking a referendum through petitions. When the city denied this request, the plaintiff filed for an injunction and a mandate for referendums in the Washtenaw Circuit Court, which sided with the city. The Court of Appeals upheld this outcome, and the case ascended to the Supreme Court. The central legal issue involved the interpretation of the home-rule act regarding the eligibility of administrative decisions for referendums. The Supreme Court concluded that referendums are limited to legislative acts, not administrative ones like property purchases, reinforcing this interpretation with existing precedent from West v Portage. Thus, the court affirmed the decisions of the lower courts, maintaining the city's administrative authority to proceed with the acquisition without holding a referendum. The ruling was unanimous, with no costs allocated due to the public interest nature of the issue.
Legal Issues Addressed
Distinction Between Legislative and Administrative Actssubscribe to see similar legal issues
Application: The court applied the distinction by ruling that the city's action to buy the property was administrative, thus not qualifying for a referendum.
Reasoning: The court affirmed the lower court's ruling that the city’s action to purchase property was administrative and not subject to a referendum.
Precedent in Referendum Eligibilitysubscribe to see similar legal issues
Application: The court's decision was consistent with prior case law, specifically West v Portage, which clarifies that referendum powers do not extend to non-legislative actions.
Reasoning: This conclusion aligns with the precedent set in West v Portage, where it was determined that the power to initiate a referendum does not cover non-legislative actions.
Referendum Limitations Under Home-Rule Actsubscribe to see similar legal issues
Application: The court determined that the right to a referendum is confined to legislative acts and does not apply to administrative decisions such as real estate acquisitions.
Reasoning: The Supreme Court held that the right to referendum under the home-rule act is limited to legislative acts and does not extend to administrative decisions like real estate acquisitions.