Background
Bonita Carey-Powers and Alexis Holmes worked for the Wayne County Community College District’s police force. They sued WCCCD and its security director, Darrick Muhammad, alleging disparate treatment based on sex, a hostile work environment, and retaliation for complaints concerning Muhammad’s alleged sexual harassment.
WCCCD moved for summary disposition, arguing in part that the employees had not filed a written claim or notice of intent in the Court of Claims within one year as required by MCL 600.6431(1). The Wayne Circuit Court denied the motion. On appeal as of right, WCCCD challenged the ruling on the ground that the employees had failed to satisfy that notice requirement.
The Court’s Holding
The Court of Appeals affirmed. It held that WCCCD is not “the state or any of its departments or officers” for purposes of the Court of Claims Act, so the employees were not required to comply with MCL 600.6431(1) before pursuing their claims in circuit court. Relying on Doan v. Kellogg Community College, the court explained that community college districts are locally created, locally governed, locally financed, and local in purpose; claims against them therefore do not fall within the Court of Claims’ jurisdiction.
The court rejected WCCCD’s argument that its status as a governmental entity for immunity purposes made it part of the state under the Court of Claims Act. Michigan’s governmental-immunity statute classifies a community college district as a political subdivision. Although both the state and political subdivisions may qualify as governmental agencies for tort-immunity purposes, those categories are not interchangeable. The court also agreed that Christie v. Wayne State University applies retroactively, but concluded that Christie did not control the outcome because WCCCD is a local political subdivision rather than the state.
Key Takeaways
- The Court of Claims Act’s one-year notice requirement does not apply to claims against a Michigan community college district.
- A community college district’s potential governmental immunity does not transform it from a political subdivision into the state.
- The court affirmed only on the Court of Claims notice issue and declined to address inadequately presented arguments concerning the merits and the ordinary limitations period.
Why It Matters
The published decision confirms that employees and other claimants suing Michigan community college districts need not first file a claim or notice of intent with the Court of Claims under MCL 600.6431(1). It preserves the distinction between locally organized political subdivisions and state entities even when both receive protections under governmental-immunity law.
For employment practitioners, the ruling prevents community college districts from using the state-specific Court of Claims notice provision to defeat otherwise viable civil-rights claims filed in circuit court.