George Badeen v. Par Inc

Michigan Court of Appeals·Decided September 10, 2026·No. 371851·Unpublished

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

GEORGE BADEEN and MIDWEST RECOVERY UNPUBLISHED AND ADJUSTMENT, INC., on Behalf of September 10, 2026 Themselves and All Others Similarly Situated, 2:01 PM

Plaintiffs-Appellants,

v No. 371851 Wayne Circuit Court

PAR NORTH AMERICA, doing business as PAR, LC No. 10-004053-CZ INC., REMARKETING SOLUTIONS, CENTERONE FINANCIAL SERVICES, LLC, MILLENIUM CAPITAL AND RECOVERY CORP., RENOVO SERVICES, LLC, RENAISSANCE RECOVERY SOLUTIONS, INC., ASR NATIONWIDE, LLC, THE M. DAVIS CO., INC., doing business as USA RECOVERY SOLUTIONS, REPOSSESSORS, INC., NATIONAL ASSET RECOVERY CORP., TD AUTO FINANCE, LLC, TOYOTA MOTOR CREDIT CORP., NISSAN MOTOR ACCEPTANCE CORP., SANTANDER CONSUMER USA, INC., PNC BANK, NA, BANK OF AMERICA, NA, FIFTH THIRD BANK, and THE HUNTINGTON NATIONAL BANK,

Defendants-Appellees,

and

FIRST NATIONAL REPOSSESSORS, INC., MV CONNECT, LLC, doing business as IIA, LLC, AMERICAN RECOVERY SERVICE, INC., DIVERSIFIED VEHICLE SERVICES, INC., CONSUMER FINANCIAL SERVICES, LLC, GE MONEY BANK, EVAN BURKHOLDER, CENTERONE DEBT MANAGEMENT SERVICES LLC, CHRYSLER CREDIT CORP., and NATIONAL CITY CORP.,

Defendants.

Before: M. J. KELLY, P.J., and O’BRIEN and LIEVENSE, JJ.

PER CURIAM.

In this putative class action, plaintiffs, George Badeen and Midwest Recovery and Adjustment, Inc., on behalf of themselves and all others similarly situated, appeal as of right the trial court’s order dismissing plaintiffs’ claims against the nearly three dozen defendants. Plaintiffs assert eight separate counts and are seeking damages from defendants, at least in part, for defendants’ supposed violations of the Occupational Code, MCL 339.101 et seq., and the Regulation of Collection Practices Act (RCPA), MCL 445.251 et seq. Each of those statutes provide for recovery of actual damages or a minimum amount of recovery regardless of actual damages incurred. In Rodriguez v Hirshberg Acceptance Corp, 341 Mich App 349; 991 NW2d 217 (2022) (Rodriguez I), vacated 514 Mich 906 (2024), this Court held that MCR 3.501(A) barred class actions premised on statutes that provide for minimum amounts of recovery regardless of actual damages unless the statutes expressly permit recovery through class actions. Because neither the Occupational Code nor the RCPA expressly permit recovery through class action, the trial court reasoned that it was required to dismiss plaintiffs’ claims on the basis of Rodriguez I.

On appeal, plaintiffs rightly note that Rodriguez I is no longer binding because it was vacated, and they ask this Court to reject Rodriguez I’s interpretation of MCR 3.501(A)(5) and to instead read that court rule as permitting this class action because it seeks actual damages. That is, plaintiffs argue that MCR 3.501(A)(5) only bars class actions that seek a minimum amount of recovery regardless of actual damages, so class actions under the Occupational Code and the RCPA seeking actual damages are permissible. Plaintiffs further contend that regardless of how MCR 3.501(A)(5) is interpreted, their individual claims and other potential class-action claims should be allowed to proceed.

Consistent with Rodriguez I, we hold that MCR 3.501(A)(5) precludes class actions seeking to recover damages under statutes that mandate a minimum amount of recovery regardless of actual damages incurred and do not expressly permit recovery through class actions, like the Occupational Code and the RCPA. The trial court thus properly dismissed plaintiffs’ class action to the extent that plaintiffs sought to recover damages for violations of the Occupational Code and the RCPA. We decline to address whether MCR 3.501(A)(5) precludes plaintiffs’ other class- action claims (if any) because we conclude that this issue is not properly before us, but we conclude that MCR 3.501(A)(5) does not preclude plaintiffs’ individual claims, so the trial court erred by dismissing plaintiffs’ other claims against defendants on grounds that it was required by MCR 3.501(A)(5) to do so. We therefore affirm in part, vacate in part, reverse in part, and remand for further proceedings.

I. BACKGROUND

This is not the first time that this case has been through this state’s appellate courts. This case centers around practices in the debt-collection business, and in a prior appeal, our Supreme Court set forth the basic facts concerning the parties’ roles in that business:

For many years, the collection industry involved two players: the creditors and the collection agents that they hired to collect debts. But in the late 1990s, as the collection industry evolved, a middleman emerged. These middlemen—known as forwarders or forwarding companies—operate as intermediaries between creditors and local collection agents. The forwarding companies’ business model involves obtaining assignments of unpaid accounts from creditors and then allocating the collection of those accounts to local collection agents. The forwarding companies do not, however, contact debtors themselves.

* * *

Plaintiff George Badeen, a licensed collection agency manager, owns and operates Midwest Recovery and Adjustment, Inc., a licensed collection agency doing business in Michigan. The primary business of Midwest Recovery is repossessing automobiles when it is assigned a delinquent account by a financing company.

This dispute’s origins lie in the shifting landscape of collection practices.

In the past, when a creditor needed a debt collected or something repossessed, it would contact and retain a collection agent wherever the debtor was located. But the business model has changed with the introduction of forwarding companies. Now forwarding companies act as middlemen between the lenders and the local collection agents. The forwarding companies operate nationwide, and when a creditor needs a collection, it contracts with a forwarding company, which, in turn, allocates the collection to a collection agent in the appropriate location. The forwarding companies maintain networks of collection agents and negotiate favorable rates that save creditors money and allow the forwarding companies to make a profit. Plaintiffs allege that this business model negatively affects licensed local collection agents. [Badeen v PAR, Inc, 496 Mich 75, 78-81; 853 NW2d 303 (2014).]

Plaintiffs also believed that certain aspects of this business model violated the Occupational Code and the RCPA. As a result, in 2010, plaintiffs filed suit seeking certification of a class comprised of automobile repossession entities that held Michigan debt-collection licenses, and, on behalf of themselves and the proposed class, plaintiffs sought to recover damages from defendants for defendants’ alleged violations of the Occupational Code and the RCPA, among other bases for relief.

What followed was a lengthy procedural history that took this case up to our Supreme Court, back to the trial court, then to federal court, where it went up to the United States Supreme Court, until the case eventually landed back in state trial court. During that time, this Court decided

Rodriguez I, which interpreted MCR 3.501(A)(5) to mean that “when a statute provides for a minimum penalty irrespective of actual damages, no class action may be maintained on the basis of that statute.” Rodriguez I, 341 Mich App at 358. So, back in the trial court, defendants moved for summary disposition under MCR 2.116(C)(8), citing Rodriguez I and arguing that, because the Occupational Code and the RCPA provide for a minimum penalty irrespective of actual damages, MCR 3.501(A)(5) barred plaintiffs’ class action based on those statutes. At the hearing on this motion, plaintiffs’ counsel admitted that Rodriguez I was controlling, and the trial court subsequently entered an order dismissing plaintiffs’ case in its entirety.

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