Calhoun County v. City of Battle Creek

Citation: Not availableDocket: 354857

Court: Michigan Court of Appeals; September 2, 2021; Michigan; State Appellate Court

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If marked "FOR PUBLICATION," this opinion is subject to revision until its final publication in the Michigan Appeals Reports. The Michigan Court of Appeals addressed a case where the City of Battle Creek was required by statute to provide a suitable place for court proceedings and a jail at no cost to Calhoun County. This statutory obligation originated from a 1905 law and was later reenacted in 1961 under MCL 600.1513, outlining the responsibilities of Battle Creek to facilitate court operations. In 2018, Battle Creek ceased payments for certain jail beds, prompting the county to file a lawsuit. The city argued that MCL 600.1513(4) constituted an unconstitutional local or special act, necessitating citizen approval, which had not occurred. The circuit court sided with the city, dismissing the case. However, the appeals court determined that the state court system is overarching and that the statute is a general act that does not require local voter approval. Consequently, the appellate court vacated the circuit court's order and remanded the case for further proceedings. The history of court sessions in Calhoun County has included regular terms in both Battle Creek and Marshall since 1905, with the structure reaffirmed in the 1961 Revised Judicature Act, maintaining the requirement for Battle Creek to host court sessions and provide jail facilities.

The circuit court has the authority to adjourn sessions and continue them at different locations. The city of Battle Creek is obligated to provide, at no cost to Calhoun County, a suitable courthouse, jail, and a secure location for court records. For 87 years, Battle Creek fulfilled this obligation until a 1992 agreement led to the construction of a new courthouse and jail, with Calhoun County covering the costs, contrary to MCL 600.1513(4). In exchange, Battle Creek provided free dispatch services and jail access for city prisoners. Following the establishment of the Calhoun County Consolidated Dispatch Authority in 2010, a new arrangement required the city to pay for jail space. In 2015, Battle Creek challenged the constitutionality of the funding arrangement, agreeing to a temporary payment plan while the legal issue was addressed. The Calhoun County Prosecutor sought an Attorney General's opinion on MCL 600.1513's relevance, which confirmed that the statute remains in effect, mandating Battle Creek to provide a courthouse and jail for the 37th Circuit Court. This requirement ensures that individuals incarcerated during court terms are readily accessible. The Attorney General's opinion also referenced legislative history, indicating that the law was designed to prevent the county from maintaining courthouses and jails in multiple locations, as the county seat was in Marshall.

After the 1971 amendment to MCL 45.16, Calhoun County gained the authority to locate its county jail anywhere within the county, while the county courthouse remained mandated to be in the county seat. This amendment does not conflict with MCL 600.1513, which requires Battle Creek to provide a suitable jail for the duration of the circuit court's term. The obligations of Calhoun County under MCL 45.16 are distinct from those of Battle Creek under MCL 600.1513, and actions taken by Calhoun County cannot invalidate Battle Creek's responsibilities. 

Subsequently, Battle Creek declined to fund the housing of city prisoners in the county jail, prompting the county to file a lawsuit seeking a declaration on the validity of MCL 600.1513 and seeking compensation based on unjust enrichment, quantum meruit, and conversion theories. Battle Creek sought summary dismissal, arguing that MCL 600.1513 was an unapproved special or local act, violating the Michigan Constitution, specifically Const 1963, art 4, § 29, which requires voter approval for such acts. 

The circuit court ruled that MCL 600.1513 was unconstitutional as a local or special act that had not been voted on by Battle Creek's citizens and dismissed the county's complaint. The county appealed this decision, which the circuit court held in abeyance pending the appeal's resolution. The appeal involves a de novo review of the circuit court’s summary dismissal and the constitutionality of MCL 600.1513, with the presumption of constitutionality as a guiding principle. The statute directly addresses Calhoun County and Battle Creek but pertains to the management of the 37th circuit court, a matter of statewide concern, thus classifying it as a general act.

In Whallon v Ingham Circuit Judge, the Michigan Supreme Court upheld the Legislature's authority to determine the location of court sessions, affirming that the circuit court operates under general common-law jurisdiction as a state court rather than a local one. The court emphasized that there is no constitutional limitation preventing the Legislature from establishing or modifying court locations, noting the necessity for convenience in serving the public. The ruling referenced MCL 600.1511 and MCL 600.1513, which mandate that Lansing provide facilities for the Ingham Circuit Court, and acknowledged the relevance of the case despite constitutional changes regarding local acts.

The Supreme Court's decision in Hart v Wayne Co further reinforced the notion that judicial funding represents a state interest rather than a local concern. In Hart, the court determined that the funding of recorder’s court judges was a general matter, reflecting the overarching state authority over judicial functions. The court's historical perspective highlighted that counties do not possess exclusive control over judicial administration, as the delivery of justice benefits the entire community. The court concluded that the establishment of appropriate facilities, such as a jail adjacent to a courthouse, is crucial for effective justice administration and public safety.

Ultimately, the ruling determined that MCL 600.1513 is a general act, rejecting the circuit court's contrary conclusion and its dismissal of the county's complaint. The Supreme Court vacated the dismissal and remanded the case for further consideration of the remaining arguments, without retaining jurisdiction.