Craig Williamson v. City of Riverview

CourtMichigan Court of Appeals
DecidedApril 24, 2025
Docket368047
StatusUnpublished

This text of Craig Williamson v. City of Riverview (Craig Williamson v. City of Riverview) 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
Craig Williamson v. City of Riverview, (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

CRAIG WILLIAMSON, UNPUBLISHED April 24, 2025 Plaintiff-Appellant/Cross-Appellee, 9:46 AM

V No. 368047 Wayne Circuit Court CITY OF RIVERVIEW, LC No. 19-015556-CD

Defendant-Appellee/Cross-Appellant.

Before: MALDONADO, P.J., and CAMERON and YOUNG, JJ.

PER CURIAM.

Plaintiff, Craig Williamson, was a firefighter for defendant, the city of Riverview. After several decades working for defendant, plaintiff observed what he believed to be timecard fraud among some of his colleagues. Plaintiff raised these concerns with his superiors and alleged, through a series of three complaints filed in the circuit court, that defendant’s response to plaintiff’s timecard fraud allegations amounts to violations of the Whistleblowers’ Protection Act (WPA), MCL 15.361 et seq. In the present case, plaintiff appeals as of right the trial court’s order granting defendant’s1 motion for summary disposition as to the latter two complaints pursuant to MCR 2.116(C)(7) (statute of limitations). We reverse and remand for further proceedings consistent with this opinion.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

Plaintiff suspected that another firefighter was inflating the hours worked on his timecard, and reported these suspicions to the fire department’s chief and deputy chief. According to plaintiff, this resulted in a number of retaliatory actions against him. On May 30, 2018, plaintiff filed his first complaint in the Wayne Circuit Court, alleging the retaliatory actions taken against

1 Plaintiff’s original complaint named both the city of Riverview and the Riverview Fire Department as defendants. However, the trial court held that the latter was not an entity subject to being sued, and plaintiff does not challenge that ruling on appeal. Accordingly, we will refer to a singular defendant throughout this opinion.

-1- him for minor missteps violated the WPA. In October 2018, the fire department charged plaintiff with violations of staffing policies; after a hearing, the fire department suspended plaintiff for 90 days and demoted him to lieutenant. On November 26, 2018, plaintiff filed a supplemental complaint, alleging additional violations of the WPA related to the staffing issue.

On August 28, 2019, defendant filed a motion for summary disposition under MCR 2.116(C)(7) (statute of limitations), (C)(8) (failure to state a valid claim), and (C)(10) (no genuine issue of material fact). On December 2, 2019, the trial court entered an order granting the motion. Plaintiff appealed to this Court, which affirmed on the grounds that plaintiff had failed to offer sufficient evidence of a causal relationship between protected conduct and any adverse employment action, or to establish that defendant’s actions were a pretext for unlawful discrimination. Williamson v Riverview Fire Dep’t, unpublished per curiam opinion of the Court of Appeals, issued May 13, 2021 (Docket No. 352771), p 6, 10. Plaintiff then appealed to our Supreme Court, which denied leave. Williamson v Riverview Fire Dep’t, 508 Mich 968; 965 NW2d 529 (2021).

On November 19, 2019, after oral argument on the motion for summary disposition but before entry of the final order in the 2018 case, plaintiff filed his complaint in this case. The first 98 paragraphs of this complaint restated the facts that formed the basis of 2018 case, after which plaintiff alleged that since he “filed this lawsuit” he had been suspended, demoted, and “written up extensively for exceedingly minor offenses.” He alleged that defendant had taken adverse actions related to the 2018 case, such as scheduling a disciplinary hearing for the date of oral argument on the motion for summary disposition in the 2018 case, and reporting two recordings he produced in discovery to the State Police for investigation.

Plaintiff also alleged that he had suffered further disciplinary actions since the dismissal of the 2018 case and continued to suffer damages in the form of reduced wages. Plaintiff asserted that defendant discriminated against him by suspending or terminating him and that a causal connection existed between his protected activity and the discrimination he endured. Plaintiff contended that any reason defendant proffered for this discrimination was pretextual. Plaintiff sought actual damages, exemplary damages, interest, costs, and attorney fees, as well as declaratory relief ordering defendant to conduct a public audit of plaintiff’s allegations for the previous five years.

In lieu of answering the complaint, defendant filed a motion for summary disposition under MCR 2.116(C)(7) (prior judgment) and (C)(8), asserting that plaintiff’s complaint raised allegations identical with those already decided in the 2018 case, and therefore that the new action was barred by the doctrines of res judicata and collateral estoppel, and that the complaint failed to state a claim under the WPA.

The following day, plaintiff filed a motion to amend his complaint “to add additional work consequences to which plaintiff has been subjected since the filing of his action.” In his supporting brief, plaintiff asserted that defendant had retaliated against him by suspending him shortly after he filed the complaint in this case, and that defendant would suffer no prejudice if the court allowed the amendment. As Exhibit A, plaintiff submitted a proposed amended complaint, alleging additional facts and violations of the WPA. Plaintiff alleged that defendant forced him to work alone or with only one other firefighter, had discriminated against him by suspending him on

-2- December 23, 2019, because he was asking co-workers to support him in this lawsuit, and had treated him “like a pariah in the workplace” since 2015 and continuing until his recent suspension. Plaintiff alleged that his “work environment has become hostile, intolerable and unsafe for Plaintiff as a result of Defendant’s retaliation.”

Defendant responded that the amendment would be futile because it merely restated the allegations made in the 2018 case, except those relating to plaintiff’s alleged suspension in December 2019. Defendant also argued that the amended complaint failed to state a viable claim under the WPA. On May 4, 2020, the trial court denied defendant’s motion for summary disposition without prejudice, and granted plaintiff’s motion to amend the complaint. Plaintiff filed an amended complaint and Defendant answered, denying the allegations as untrue, and asserting that the allegations in both counts were subject to the court’s decision in the 2018 case. Among its affirmative defenses, defendant argued plaintiff’s claims were barred by res judicata, collateral estoppel, and the applicable statute of limitations.

Defendant again filed a motion for summary disposition, asserting that plaintiff’s claims, other than those relating to the alleged December 2019 suspension and plaintiff’s current work environment, were barred under MCR 2.116(C)(6).2 Defendant asserted that plaintiff’s other claims were barred by res judicata, collateral estoppel, and the statute of limitations, and requested dismissal with prejudice of all claims that were, or could have been, raised in the 2018 case. In September 2020, the trial court entered an order staying proceedings in this case pending resolution of plaintiff’s appeal of the 2018 case.

On October 15, 2021, while proceedings in this case were stayed, plaintiff filed a third action under the WPA against defendant (the 2021 case).

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Bluebook (online)
Craig Williamson v. City of Riverview, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craig-williamson-v-city-of-riverview-michctapp-2025.