Miller v. Michigan Department Of Corrections (Opinion - Leave Granted)
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Two employees, Richard Miller and Brent Whitman, filed a lawsuit against the Michigan Department of Corrections (MDOC), alleging they were terminated in retaliation for their close friendship with Cedric Griffey, a deputy warden who was targeted by the MDOC after his wife, Lisa Griffey, filed a complaint and lawsuit against the MDOC for racial harassment. The plaintiffs claimed their termination was a violation of the Elliott-Larsen Civil Rights Act (ELCRA).
The Genesee Circuit Court denied the MDOC's motion for summary disposition, which argued that the plaintiffs had failed to state a claim under the ELCRA because they had not personally engaged in any protected conduct. The MDOC appealed this decision, and the Court of Appeals reversed the lower court's ruling, concluding that the ELCRA did not authorize the plaintiffs' claims.
The Michigan Supreme Court, however, disagreed with the Court of Appeals. The Supreme Court held that the ELCRA does provide a cause of action for associational or "third party" retaliation claims. The court found that the plaintiffs had sufficiently alleged such a claim, stating that they had a close relationship with Cedric Griffey and that the MDOC took adverse action against them in response to Griffey's protected acts. The court concluded that the plaintiffs' firings were part of the effort to retaliate against Griffey, and thus, they had stated a cause of action under the ELCRA. The Supreme Court reversed the judgment of the Court of Appeals and remanded the case back to the circuit court for further proceedings.
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