Anthony Chaney v. Meritage Hospitality Group Inc

CourtMichigan Court of Appeals
DecidedSeptember 12, 2025
Docket372910
StatusUnpublished

This text of Anthony Chaney v. Meritage Hospitality Group Inc (Anthony Chaney v. Meritage Hospitality Group Inc) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anthony Chaney v. Meritage Hospitality Group Inc, (Mich. Ct. App. 2025).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

ANTHONY CHANEY, UNPUBLISHED September 12, 2025 Plaintiff-Appellee, 9:08 AM

v No. 372910 Kent Circuit Court MERITAGE HOSPITALITY GROUP, INC., doing LC No. 24-002219-NO business as WENDY’S,

Defendant-Appellant.

Before: SWARTZLE , P.J., and GARRETT and YATES, JJ.

PER CURIAM.

Plaintiff, Anthony Chaney, ate a chicken sandwich purchased at a Wendy’s restaurant. Proceeding in propria persona, he filed this action, alleging that the sandwich was tainted with E. coli bacteria and made him ill. Defendant, Meritage Hospitality Group, Inc., doing business as Wendy’s (Meritage), moved for summary disposition, arguing that Chaney failed to provide any evidence that the sandwich caused his illness. Meritage appeals by right the trial court’s order granting its motion without prejudice as opposed to with prejudice. Because the trial court’s decision was a decision on the merits, and the doctrine of res judicata precludes Chaney from refiling his action, the trial court erred by dismissing the action without prejudice. We therefore vacate the trial court’s order in part and remand for entry of an order dismissing the action with prejudice.

I. FACTS AND PROCEEDINGS

Chaney filed this action, alleging that he became ill after eating a chicken sandwich purchased at a Wendy’s restaurant in Holland, Michigan. He asserted that the sandwich was infected with E. coli bacteria and that, 18 days after he ate the sandwich, he was diagnosed with colitis as a result of eating the contaminated sandwich. Chaney alleged negligence and gross negligence (Count 1), breach of express and implied warranties (Count 2), and violation of the Michigan Consumer Protection Act (MCPA), MCL 445.901 et seq. (Count 3).

Although Meritage denied that it owned or operated the Wendy’s location where Chaney purchased the sandwich, it defended Chaney’s lawsuit. Meritage moved for partial summary

-1- disposition under MCR 2.116(C)(8) with respect to Chaney’s gross negligence, breach of express warranty, and MCPA claims. The trial court granted the motion, leaving only Chaney’s negligence and breach of implied warranty claims.

Meritage moved for summary disposition under MCR 2.116(C)(10)1 regarding the remaining claims, arguing that Chaney was unable to establish the element of causation with respect to either claim. Meritage relied on Chaney’s responses to Meritage’s discovery requests asking him to admit that no doctor diagnosed him with E. coli exposure and that he had no documentation indicating that his diagnosis of colitis resulted from the allegedly contaminated sandwich. Chaney made no admissions, but failed to produce any documentation, stating instead that discovery was ongoing.2 Meritage argued that, even if Chaney had an E. coli infection, he could only speculate where his E. coli exposure came from, which was insufficient to establish causation. Meritage also asserted that, although discovery was ongoing, summary disposition was not premature because further discovery did not stand a fair chance of uncovering factual support for Chaney’s claims.

Chaney objected to Meritage’s motion. He disputed Meritage’s claim that it did not own or operate the Wendy’s location at issue. He relied on a photo of a sticker on the door of the restaurant indicating that Meritage owned the restaurant and a photo showing that the sticker had been removed. He also relied on an ad posted on the Internet indicating that Meritage sought to hire a shift manager for the location. Further, he relied on a previously provided medical record from Spectrum Health Zeeland Community Hospital stating that he was diagnosed with colitis on February 26, 2022. He requested that the trial court deny Meritage’s motion and allow discovery to continue.

Meritage filed a reply to Chaney’s objection, arguing that Chaney failed to respond to its arguments regarding causation and provide substantively admissible evidence regarding causation. It maintained that it could not produce evidence known only to Chaney, in particular whatever led him to believe that he was infected with E. coli after eating a sandwich purchased at the restaurant and what led him to believe that E. coli caused his colitis. Meritage asserted that Chaney’s objection erroneously focused on its purported ownership or operation of the business.

During oral argument on the motion, the trial court advised Chaney, who was still proceeding in propria persona, that he needed to provide documentation indicating that the sandwich he purchased at the restaurant and consumed was tainted with E. coli and that E. coli caused his colitis. The court granted Meritage’s motion, stating that although the evidence showed that Chaney was diagnosed with colitis, nothing linked the diagnosis to E. coli, and no evidence

1 Meritage mistakenly references MCR 2.116(C)(8) in its motion, but references MCR 2.116(C)(10) in its brief supporting the motion. 2 Contrary to Meritage’s assertion, although Chaney did not produce documentary evidence in response to Meritage’s requests for admission, he did not admit that he had no documentation or proof supporting his claims.

-2- indicated that Chaney was exposed to E. coli as a result of consuming food purchased from the Wendy’s location at issue.3 The court further stated as follows:

So the question then is since this is a (C)(10) and discovery is still open, is there a fair chance that further discovery will reveal any evidence of your claim? I do not see an affidavit from you that suggests there will—there is. I have not seen any evidence from you that suggests that there’s such a fair chance for further discovery. So I do believe that although discovery has not been closed, this case is ripe for summary disposition under (C)(10).

The Court is, therefore, going to grant the defendant’s motion. Mr. Broaddus [defense counsel], I will look for an order from you—I’m going to stipulate [sic] that that motion is going to be granted without prejudice, okay? And I think that’s proper under (C)(10).

In other words, Mr. Chaney, you do have the right to refile, but understand the requirements if you do refile, and the need for you to meet your evidentiary burden under the court rules should you refile. What I’m suggesting to you is have your evidence ahead of time before you refile a case. Do not file a case, it may be deemed frivolous and it may subject you to sanctions, potentially. I need to see a link. If you’re going to file a case, there needs to be some linkage between your illness, the restaurant, having the same diagnosis in this case.

Thereafter, Meritage filed this appeal, arguing that the trial court erred by dismissing Chaney’s complaint without prejudice as opposed to with prejudice.

II. STANDARD OF REVIEW

We review de novo a trial court’s decision on a motion for summary disposition. Houston v Mint Group, LLC, 335 Mich App 545, 557; 968 NW2d 9 (2021). A motion under MCR 2.116(C)(10) tests the factual support of the plaintiff’s complaint. Anderson v Transdev Servs, Inc, 341 Mich App 501, 506; 991 NW2d 230 (2022). Summary disposition under subrule (C)(10) is properly granted when the pleadings, affidavits, depositions and other evidence, viewed in the light most favorable to the nonmoving party, fail to establish a genuine issue of material fact for trial. Id. at 506-507. “A genuine issue of material fact exists when the record, giving the benefit of reasonable doubt to the opposing party, leaves open an issue upon which reasonable minds might differ.” Id. at 507 (quotation marks and citation omitted).

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Cite This Page — Counsel Stack

Bluebook (online)
Anthony Chaney v. Meritage Hospitality Group Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anthony-chaney-v-meritage-hospitality-group-inc-michctapp-2025.