JAMES J CARTER V ANN ARBOR CITY ATTORNEY
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STATE OF MICHIGAN
COURT OF APPEALS
JAMES J. CARTER,
FOR PUBLICATION
June 27, 2006
9:00 a.m.
Plaintiff-Appellant,
v
ANN ARBOR CITY ATTORNEY,
No. 258282
Washtenaw Circuit Court
LC No. 04-346-AW
Defendant-Appellee.
Official Reported Version
Before: Fort Hood, P.J., and Cavanagh and Servitto, JJ.
SERVITTO, J.
Plaintiff appeals as of right a circuit court order granting summary disposition in favor of
defendant and denying plaintiff 's motion for summary disposition in this veterans preference act
case. Because plaintiff failed to demonstrate his ability to perform the job of assistant city
attorney at the level of skill and with the expertise required by the employer, the veterans
preference act did not grant him preference in public service employment and we therefore
affirm.
In response to a notice of job vacancies, plaintiff applied for a position as assistant city
attorney for the city of Ann Arbor. When two others were ultimately hired for the available
positions, plaintiff filed a complaint for a writ of mandamus, seeking to compel the Ann Arbor
City Attorney to employ him as an assistant city attorney. Plaintiff asserted that because he is a
veteran and qualified for the position(s), he was entitled to preference for employment under the
veterans' preference act, MCL 35.401 et seq. Plaintiff further claimed that in hiring nonveterans
rather than him, defendant violated the act. The parties filed cross-motions for summary
disposition and, as previously indicated, the trial court granted defendant's motion for summary
disposition, ruling that plaintiff failed to establish a right to mandamus and further failed to
submit materials or documentation demonstrating he had the requisite qualifications for the
positions.
This Court reviews de novo a trial court's ruling on a motion for summary disposition.
Corley v Detroit Bd of Ed, 470 Mich 274, 277; 681 NW2d 342 (2004). Summary disposition
may be granted pursuant to MCR 2.116(C)(8) on the ground that the opposing party "has failed
to state a claim on which relief can be granted." Radtke v Everett, 442 Mich 368, 373; 501
NW2d 155 (1993). In assessing a motion brought under MCR 2.116(C)(8), all factual
allegations are accepted as true, as well as any reasonable inferences or conclusions that can be
drawn from the facts. Id. In considering a motion pursuant to MCR 2.116(C)(10), a court
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considers affidavits, pleadings, depositions, admissions, and other documentary evidence
submitted by the parties in a light most favorable to the nonmoving party. Corley, supra, 470
Mich at 278. If the proffered evidence fails to establish a genuine issue of material fact, the
moving party is entitled to judgment as a matter of law. Maiden v Rozwood, 461 Mich 109, 120;
597 NW2d 817 (1999). Issues concerning the interpretation of a statute are questions of law that
we also review de novo. Dressel v Ameribank, 468 Mich 557, 561; 664 NW2d 151 (2003).
Plaintiff raises several arguments on appeal, all turning upon the interpretation and
application of the veterans' preference act (VPA). "'The primary goal of statutory interpretation
is to give effect to the intent of the Legislature.'" Title Office, Inc v Van Buren Co Treasurer,
469 Mich 516, 519; 676 NW2d 207 (2004), quoting In re MCI Telecom Complaint, 460 Mich
396, 411; 596 NW2d 164 (1999). In construing a statute, "the [C]ourt must consider the object
of the statute, the harm it is designed to remedy, and apply a reasonable construction that best
accomplishes the statute's purpose." Morris & Doherty, PC v Lockwood, 259 Mich App 38, 44;
672 NW2d 884 (2003) (citations omitted). "Unless defined in the statute, every word or phrase of
a statute will be ascribed its plain and ordinary meaning." Robertson v DaimlerChrysler Corp,
465 Mich 732, 748; 641 NW2d 567 (2002).
"The veterans' preference act was enacted for the purpose of discharging, in a measure,
the debt of gratitude the public owes to veterans who have served in the armed services in time
of war, by granting them a preference in original employment and retention thereof in public
service." Valentine v McDonald, 371 Mich 138, 144-145; 123 NW2d 227 (1963). Consistent
with that purpose, the act provides, in relevant part:
In every public department and upon the public works of the state and of
every county and municipal corporation thereof honorably discharged veteran
[sic] . . . shall be preferred for appointment and employment. Age, loss of limb, or
other physical impairment which does not, in fact, incapacitate, shall not be
deemed to disqualify them. . . . The applicant shall be of good moral character
and shall have been a resident of the state for at least 2 years and of the county in
which the office or position is located for at least one year, and possess other
requisite qualifications, after credit allowed by the provisions of any civil service
laws. . . . [MCL 35.401]
The VPA applies to veterans, like plaintiff, who served in the Vietnam era (see MCL 35.61[j])
and is to be liberally construed. Abt v Wilcox, 264 Mich 183, 185; 249 NW 483 (1933).
While the VPA clearly states that veterans shall be given a preference for appointment
and employment, it does not describe the nature or strength of the preference. Further, the VPA
provides that a veteran is not entitled to the preference unless he or she meets the residency
requirements and possesses "other requisite qualifications." However, the VPA neither defines
"other requisite qualifications" nor mandates who is responsible for determining what the
requisite qualifications are and whether an applicant possesses those qualifications. This Court,
then, must first examine the language of the VPA and determine whether the VPA grants an
absolute hiring preference to a veteran who meets the minimum job requirements for a position
in public employment (as claimed by plaintiff) or whether the public employer has discretion to
hire a better qualified nonveteran over a veteran who possesses the minimum qualifications.
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According to Random House Webster's College Dictionary (2000),1 "prefer" means:
1. to set or hold before or above other persons or things in estimation; like
better: I prefer school to work. 2. to give priority to, as to one creditor over
another. 3. to put forward or present for consideration or sanction. 4. to put
forward or advance, as in rank or office; promote.
Similarly, according to Black's Law Dictionary (8th ed), "prefer" means "to give priority to."
Further, Random House Webster's College Dictionary defines "requisite" as "required;
necessary" and defines "qualification" as "a quality, accomplishment, etc., that fits a person for
some function, office, or the like." Under the plain, ordinary meanings of the relevant words in
the VPA, defendant had to hold plaintiff above, or give plaintiff priority over, other nonveteran
applicants if he possessed the qualities or accomplishments that were required or necessary to
fulfill the role of an assistant city attorney.
Plaintiff argues that he does not have to prove his relative qualifications because of
amendments of the VPA that have taken place over the years. We disagree. Plaintiff specifically
directs this Court's attention to 1923 PA 88, an earlier version of the VPA that provided:
That the applicant shall be of good moral character and shall have been a
resident of the state for at least two years and of the county in which the office or
position is located for at least one year, and possesses other requisite
qualifications, which shall be at least equal to those of other applicants.
[Emphasis added.]
Pursuant to 1939 PA 298, the language requiring that the veteran possess other requisite
qualifications "which shall be at least equal to those of other applicants" was deleted and no
longer appeared in the statute. By deleting the phrase "which shall be at least equal to those of
other applicants," the Legislature arguably evinced its intent that the preference not be triggered
only when the veteran's qualifications were equal to the other applicants. See, e.g., Edgewood
Dev, Inc v Landskroener, 262 Mich App 162, 167-168; 684 NW2d 387 (2004). However,
though the Michigan Legislature did not intend for the preference to be triggered only when the
veteran's qualifications are equal to or better than a nonveteran's qualifications, this does not
mean that the Legislature intended for the VPA to provide an absolute preference, regardless of
qualifications.
The Michigan Supreme Court decision in Patterson v Boron, 153 Mich 313; 116 NW
1083 (1908), proves instructive on this issue. In Patterson, the plaintiff, an honorably discharged
Union soldier, sought a writ of mandamus compelling the defendant mayor to appoint him as a
1
This Court may examine dictionary definitions if a statute does not expressly define its terms.
People v Rutledge, 250 Mich App 1, 6; 645 NW2d 333 (2002).
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city attorney. The plaintiff based his right to the appointment on the VPA, as set forth in 1907
PA 329:2
In every public department, and all public departments in all municipal
corporations . . . honorably discharged soldiers, sailors and marines of the late
Rebellion . . . and the Spanish-American War shall be preferred for appointment
and employment; age, loss of limb or other physical impairment which does not,
in fact, incapacitate, shall not be deemed to disqualify them: Provided, however,
That the applicant . . . shall have been a resident of the state for at least two years
and of the county in which the office or position is located for at least one year,
and possesses other requisite qualifications. [Id. at 313-314.]
The Court noted that under the act, "discharged Union soldiers are not entitled to an
appointment unless they possess the other requisite qualifications." Id. at 314. The mayor
refused to appoint the plaintiff to the position of city attorney because, in his estimation, the
plaintiff did not possess the requisite qualifications for the position. Id. On appeal, the issue
before our Supreme Court was whether the mayor had the right to make that determination. The
Court noted that the mayor had the authority to appoint the city attorney and was likewise
authorized to refuse to appoint the plaintiff as city attorney:
This right to appoint imposed on respondent the duty of determining that
his appointee possessed the requisite qualifications for the office. He would have
been faithless to that duty had he appointed an applicant whom he deemed
disqualified. The law therefore made it his duty to determine whether relator—an
applicant for the office—possessed the requisite qualifications, and no law
authorizes a court to review his determination that relator lacked such
qualifications. It must therefore be held that relator is not entitled to the
appointment in question because it has been authoritatively determined that he
does not possess the requisite qualifications therefor. [Id. at 314-315.]
In Patterson, then, our Supreme Court clearly held that to be entitled to the veteran's
preference, a veteran must possess the requisite qualifications for the position, as determined by
the hiring authority.
Here, the city of Ann Arbor granted defendant the authority to appoint assistant city
attorneys.3 As in Patterson, the right to appoint assistant city attorneys imposes on defendant the
duty to determine that the applicants who are hired possess the requisite qualifications for the
office. Today we reaffirm the principle set forth in Patterson and hold that notwithstanding the
2
The language of the VPA at the time of Patterson, supra, was substantially similar to the
current language.
3
Section 5.2 of the charter for the city of Ann Arbor specifically provides that the city attorney
may delegate one of more duties to an assistant "who shall be appointed by the Attorney . . . ."
(Emphasis added.)
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VPA, a hiring authority is authorized to refuse to hire a veteran if, in the authority's estimation,
the veteran did not possess the requisite qualifications for the position.
We further clarify that the veteran's preference is not absolute. Although the veteran's
qualifications need not be equal to the qualifications of a nonveteran to trigger the preference, his
or her qualifications must be at least comparable. Other jurisdictions have applied their
respective veterans' preference acts in a similar fashion.4 For example, Pennsylvania's Veterans'
Preference Act (PaVPA), like the VPA, confers a preference on those who meet certain
established criteria: the applicant must be a veteran, must be honorably discharged, and must
possess the other requisite qualifications to satisfactorily perform all of the duties which the
position requires. 51 Pa Cons Stat Ann § 7101 et seq.
In Merrell v Chartiers Valley School Dist, 579 Pa 97; 855 A2d 713 (2004), the
Pennsylvania Supreme Court held that the PaVPA essentially provides for a tie-breaking
preference for candidates with comparable qualifications and, therefore, the preference does not
ripen until the veteran can establish the requisite qualifications for the position. 579 Pa at 111112. According to the Merrell court, the purpose of the PaVPA "is not to place veterans in a
better position than other applicants simply because they are veterans . . . but to provide a
preference in the final selection process among candidates of comparable quality." Merrell,
supra, 579 Pa at 112. In Brickhouse v Spring-Ford Area School Dist, 540 Pa 176; 656 A2d 483
(1995), the Pennsylvania Supreme Court further recognized that, while it was lawful to prefer
veterans in employment, "'there must be some reasonable relation between the basis of
preference and the object to be obtained, the preference of veterans for the proper performance of
public duties.'" Brickhouse, supra, 540 Pa at 181-182, quoting Commonwealth ex rel Graham v
Schmid, 333 Pa 568, 573; 3 A2d 701 (1938). See also Gossage v State, 112 Wash App 412, 422;
49 P3d 927 (2002) (argument that veterans preference is absolute ignores that the preference
requires that the applying veteran possess the capacity necessary to discharge the duties of the
position involved).
We find the logic employed by the Pennsylvania Supreme Court persuasive and sound.
Public employers should not be required to hire veterans who meet the bare minimum job
qualifications if they do not believe the veteran is, in fact, qualified for the position or that the
veteran does not possess the requisite experience. In this particular matter, hiring an assistant
city attorney who does not possess the qualities found necessary by defendant could undermine
the integrity of the position and have an undesirable impact on Ann Arbor residents who rely on
the city attorney's office to perform at a particular level of expertise so as to best serve the
public's interests. To grant an absolute preference to veterans, then, would be to ignore the
consequences of hiring unqualified persons in public employment.
In sum, although the veteran's qualifications need not be equal to the qualifications of a
nonveteran to trigger the preference, the veteran's qualifications must be at least comparable in
the estimation of the hiring authority. The veteran's preference, then, does not ripen until the
4
Lacking guidance under Michigan law, we may look to other states' case law interpreting
similar statutes. In re Turpening Estate, 258 Mich App 464, 466; 671 NW2d 567 (2003).
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veteran can establish that he or she possesses the requisite qualifications for the position and the
VPA does not preclude a public employer from hiring a nonveteran applicant if the employer
reasonably believes that the nonveteran applicant is substantially better qualified than the
veteran.
Plaintiff 's argument that defendant was obligated to hire him because he possessed the
"must-have" qualifications posted in the job notice thus fails. Although those qualifications may
have established plaintiff 's eligibility to be considered for the position, those qualifications did
not establish that he was "qualified" for the job. The minimum requirements are very basic
(licensed to practice law in Michigan; two years' experience as an attorney; good research,
writing, and oral advocacy skills; work well independently and learn quickly; familiarity with
computer-based legal research and computer programs); therefore, to follow plaintiff 's logic
would leave defendant absolutely no discretion to consider specific experience or expertise that
may be required to adequately perform the job. Again, defendant was given the discretion (and,
indeed, had a duty according to Patterson) to set the requisite qualifications for a position and
determine whether the candidates possessed such qualifications. Absent this discretion, and
under plaintiff 's reading of the VPA, any other part of the hiring process (interview, background
check, etc.) would be rendered pointless, as once a veteran applicant met the bare minimum
requirements, the hiring body would be compelled to hire the veteran and the hiring process
would effectively cease. This would clearly be inconsistent with the policies and purposes
behind the VPA.
The above being true, this Court turns its attention to whether plaintiff possessed the
required qualifications for the position of assistant city attorney and whether his qualifications
were comparable to those of the other applicants. The posting for the job of assistant city
attorney reads as follows:
JOB SUMMARY The Assistant City Attorney is a staff attorney in the
City Attorney's Office and serves as Attorney for the City. Specific assignments
and other duties depend on the attorney's skills and the needs of the office, but
will include review of legal documents, written and oral advice on a variety of
legal issues, and representation of the City in court and/or administrative
proceedings. This is a full-time position, however part-time placement will be
considered.
EDUCATION AND EXPERIENCE Min[imum] of two (2) years of
experience as an attorney. Experience in municipal law practice preferred.
Experience desired in one or more of the following areas of law: collections; tax;
planning and zoning; ordinance enforcement or other prosecution or defense
experience; litigation; environmental, water and sewer utilities; labor and
employment. Experience interacting with and advising public bodies such as
boards and commissions desired. Must have good research, writing, oral
advocacy, and interpersonal skills, must work well independently, and must be
able to learn new areas of law quickly. Must be able to do computer based legal
research. Must have some familiarity with and ability to use word processing,
database, spreadsheet and other computer programs desirable. Must be licensed
to practice law in Michigan.
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After submitting his application, plaintiff received correspondence from defendant
indicating that he was going to collect and review resumes over the next few months and
determine the specific needs of the office.5 Defendant's affidavit indicates that he ultimately
determined that the office required one attorney with experience in labor issues and one with
experience in zoning and planning. Moreover, defendant established specific hiring criteria for
each position. According to defendant, the minimum qualifications, although not specified in the
initial general posting for the positions, were as follows:
Labor Law Attorney—significant traditional labor experience with a high
level of responsibility in a corporate or municipal setting and experience with
arbitration hearings, the National Labor Relations Board and/or the Michigan
Employment Relations Commission, labor negotiations, and collective bargaining
agreement.
Zoning and Planning Attorney—experience with zoning and planning
issues, significant involvement with Planning Commission issues, ability to work
well with Planning Commission, planning department, and community
development staff.
Plaintiff 's resume indicates his areas of expertise as including: all areas of real estate and
construction law; general business, including contracts, partnerships, corporations and limited
liability companies; tax law (particularly in the area of real estate); and employment law. While
plaintiff 's resume indicated that he "[c]ompleted courses and internship in public sector labor
law," his application materials did not indicate that he had experience in labor law or zoning and
planning law. In light of his application and resume, then, plaintiff did not have the requisite
qualifications for either position.
The applicants who were ultimately hired, on the other hand, provided information
demonstrating their qualifications for the positions. The applicant hired as a labor attorney, for
example, had eight years of experience with Dykema Gossett PLLC representing public and
private employers in traditional union matters, and an additional eight years of experience as a
manager for labor and employment at DTE Energy and an attorney at Michigan Consolidated
Gas Company, where she represented the companies before the National Labor Relations Board
and negotiated collective bargaining agreements. The applicant hired for the zoning and
5
While plaintiff contends defendant is bound by the wording of the official job posting, he has
provided no relevant authority to support such a position. Moreover, plaintiff has failed to direct
this Court's attention to any provision in the city's affirmative action plan tending to indicate that
defendant must include every possible qualification in a job posting, prohibiting defendant from
considering qualifications other than those set forth in the posting, or otherwise restricting the
discretion of defendant in hiring assistants. A party may not merely announce its position and
leave it to the court to discover and rationalize the basis for its claims, Wilson v Taylor, 457 Mich
232, 243; 577 NW2d 100 (1998), "nor may he give issues cursory treatment with little or no
citation of supporting authority." Houghton v Keller, 256 Mich App 336, 339; 662 NW2d 854
(2003).
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planning position demonstrated experience in that area, including having held a position with the
Ann Arbor Planning Commission for five years and prior experience with federal housing law.
Defendant was seeking to hire two attorneys to practice in specific areas of the law: labor
law and zoning and planning law—not a general lawyer with experience in a multitude of
practice areas. Therefore, regardless of plaintiff 's experience in other areas of the law, plaintiff 's
lack of experience in labor law and zoning and planning law is fatal to his claim that his
qualifications were comparable to or greater than those of the successful applicants. Because
plaintiff failed to establish that he possessed the "other requisite qualifications" set forth by
defendant, he was not entitled to the veteran's preference. In other words, plaintiff failed to
demonstrate that he had the ability to perform the job at the level of skill and with the expertise
demanded by defendant, the employer, and thus, the preference never ripened. And, because
there was no preference for plaintiff to enforce, the trial court properly granted summary
disposition in favor of defendant.
The trial court also properly found that plaintiff failed to establish a right to mandamus in
this matter. A trial court's decision whether to issue a writ of mandamus is reviewed for an abuse
of discretion. MCI, supra, 460 Mich at 443. But whether defendant had a clear legal duty to
perform and whether plaintiff had a clear legal right to the performance of that duty, thereby
satisfying the first two steps in the test for assessing the propriety of a writ of mandamus, are
questions of law, which this Court reviews de novo. Tuggle v Dep't of State Police, 269 Mich
App 657, 667; 712 NW2d 750 (2006), citing Citizens for Protection of Marriage v Bd of State
Canvassers, 263 Mich App 487, 491-492; 688 NW2d 538 (2004). Moreover, an underlying
issue of statutory interpretation is a question of law that is reviewed de novo on appeal. MCI,
supra, 460 Mich at 443.
In Vorva v Plymouth-Canton Community School Dist, 230 Mich App 651, 655; 584
NW2d 743 (1998), this Court explained that the issuance of a writ of mandamus is only proper
where:
(1) the plaintiff has a clear legal right to performance of the specific duty
sought to be compelled, (2) the defendant has the clear legal duty to perform such
act, and (3) the act is ministerial, involving no exercise of discretion or judgment.
Bingo Coalition for Charity—Not Politics v Bd of State Canvassers, 215 Mich
App 405, 413; 546 NW2d 637 (1996). Mandamus is an extraordinary remedy
that may lie to compel the exercise of discretion, but not to compel its exercise in
a particular manner. Teasel v Dep't of Mental Health, 419 Mich 390, 409-410;
355 NW2d 75 (1984).
Plaintiff bears "the burden of demonstrating entitlement to the extraordinary remedy of a writ of
mandamus." Citizens for Marriage, supra, 263 Mich App at 492.
The VPA provides:
In case the application of any such soldier, sailor or marine, shall be
rejected by the person having the power of appointment to the position for which
he has applied, he shall be entitled to remedy therefor by mandamus to enforce
the provisions of this act. [MCL 35.404.]
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Applying Vorva, supra, to the facts of this case, plaintiff failed to demonstrate that he
was entitled to a writ of mandamus. First, plaintiff failed to establish that he had a clear legal
right to be hired by defendant. As discussed above, he failed to demonstrate that he possessed
the requisite qualifications for the position and, therefore, he had no right to further consideration
by defendant. Second, defendant did not have a clear legal duty to hire plaintiff. He did not
have a duty to hire any individual whom he determined did not have the ability to perform the
job at the level of skill and with the expertise demanded by defendant. Third, and most
importantly, plaintiff failed to establish that the act of hiring an assistant city attorney was a
ministerial task. An act is ministerial in nature if it is "'prescribed and defined by law with such
precision and certainty as to leave nothing to the exercise of discretion or judgment.'" Beadling v
Governor, 106 Mich App 530, 533; 308 NW2d 269 (1981), quoting Oakland Schools Bd of Ed v
Superintendent of Pub Instruction, 401 Mich 37, 43-44; 257 NW2d 73 (1977).
In support of his contention that the act of hiring an assistant city attorney is a ministerial
task, plaintiff cites McMullen v Saginaw City Manager, 300 Mich 166; 1 NW2d 494 (1942). In
McMullen, the trial court issued a writ of mandamus requiring the managing officer of the city to
appoint two civil service commissioners to regulate the employment of members of the city fire
department. Id. at 167. Under a public act adopted and made operative in that city, the civil
service commission was to consist of three members, two of whom were to be appointed by the
person or group acting as a mayor, city manager, council, or common council. Id. at 169. The
other member was to be selected by the paid members of the fire department. Id. The paid
members of the fire department made their selection, but the city manager, by refusing to appoint
the other two members of the commission, prevented operation of the act. Id. The city appealed
the issuance of the writ arguing, among other things, that the writ "abridge[d] the right of
municipal home rule." Id. at 168. Our Supreme Court held that the writ was properly issued
because the act was operative in the city and the act "command[ed] appointment of
commissioners by the city." Id. at 169-170.
McMullen is clearly distinguishable from the case at hand. The act in McMullen required
the managing officer to appoint two commissioners—an action that was mandatory and, thus,
ministerial. The writ of mandamus did not, however, require appointment of any specific
individuals (a decision presumably left to the discretion of the managing officer) but rather
required simply that commissioners be appointed as required by the operative act.
In the instant case, neither the Ann Arbor charter nor the VPA required defendant to hire
any assistant city attorneys at all. Instead, defendant had the discretion to hire the assistant city
attorneys. Moreover, the writ sought by plaintiff was for appointment of himself, a specific
individual, as assistant city attorney. The choice of an assistant, however, was discretionary.
See, e.g., Patterson, supra, 153 Mich at 314-315.
The remaining cases cited by plaintiff for the proposition that the appointment of an
assistant city attorney is a ministerial task are similarly distinguishable. As in McMullen, People
ex rel Attorney General v Detroit Common Council, 29 Mich 108 (1874) involved a writ
compelling council to act on a clear legal duty (by considering nominations made by the mayor
to establish a board of public works). Meiland v Wayne Probate Judge, 359 Mich 78; 101 NW2d
336 (1960), also cited by plaintiff, involved the reinstatement of an employee in a civil service
position that he was clearly qualified to occupy. The ultimate decision in Meiland was based on
civil service rules, which are not applicable in this case.
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A writ of mandamus is not appropriate when the act that the plaintiff seeks to compel the
defendant to perform is a discretionary one. See Tuscola Co Abstract Co, Inc v Tuscola Co
Register of Deeds, 206 Mich App 508, 512; 522 NW2d 686 (1994) ("mandamus was
inappropriate[ ] because defendant's actions involved the exercise of discretion vested in a public
official"). Because the hiring of assistant city attorneys is discretionary, and because plaintiff
failed to establish that he had a clear legal right to be hired by defendant or that defendant had a
clear legal duty to hire plaintiff, the writ of mandamus was properly denied.
Affirmed.
/s/ Deborah A. Servitto
/s/ Karen M. Fort Hood
/s/ Mark J. Cavanagh
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