Hart v. Wayne County

232 N.W.2d 678, 61 Mich. App. 188, 1975 Mich. App. LEXIS 1517
CourtMichigan Court of Appeals
DecidedMay 28, 1975
DocketDocket No. 19285
StatusPublished
Cited by2 cases

This text of 232 N.W.2d 678 (Hart v. Wayne County) 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
Hart v. Wayne County, 232 N.W.2d 678, 61 Mich. App. 188, 1975 Mich. App. LEXIS 1517 (Mich. Ct. App. 1975).

Opinion

Bronson, P. J.

The County of Wayne has funded portions of the salaries of Detroit Recorder’s Court judges for 55 years. The legality of that well-established practice is challenged in this appeal.

Appellant can hardly take credit for this, however. He has failed to submit a brief in accordance with GCR 1963, 813. We have been given a sheaf of papers labeled "brief’, but careful and repeated readings of its contents have as yet served no purpose. Appellant’s one-paragraph "argument” is simply a series of unsupported conclusions. If this were the usual case, we would hold that appellant’s failure to file a brief constitutes issue abandonment. Mitcham v Detroit, 355 Mich 182, 203; 94 NW2d 388 (1959).

But this is not the usual case. The trial judge, the principal defendants, and the intervening defendants have done an excellent job in developing, researching, and analyzing the troublesome issues presented here. We have also been favored with a comprehensive, scholarly opinion by the trial judge. Because this case involves the important question of the constitutionality of a state statute, because its resolution affects all of the residents of Wayne County, and because it has been properly prepared for decision, plaintiffs failure to shoulder his appellate burden should be ignored.

The parties agree that this case involves solely a question of law and can appropriately be disposed of by summary judgment. We proceed to consider whether the trial judge erred in entering summary judgment on behalf of defendants rather than plaintiff.

[191]*191I.

Prior to 1920, the judges of the Recorder’s Court of the City of Detroit were paid pursuant to MCLA 726.6; MSA 27.3556, which provides, in pertinent part:

"Each of said judges shall receive from the treasury of the state of Michigan the same annual salary as may be payable to circuit judges. * * * ” (Emphasis added.)

In 1919, the Michigan Legislature enacted PA No. 369. This act was enabling legislation designed to permit our cities to establish municipal courts and to allow municipalities already possessing municipal courts to adopt the procedural alterations it contained. Section 13 of the 1919 act1 provides, in relevant part:

"Each judge of said court, including the presiding judge, shall receive an annual salary from the county in which said court is located in the same amount as that paid by the State to circuit judges * * * .”2(Emphasis supplied.) On April 5, 1920 the 1919 act was approved by a majority of the electorate of the City of Detroit.3

Since Recorder’s Court is the municipal court for the City of Detroit, People v Buckley, 302 Mich 12, 18; 4 NW2d 448 (1942), Moline v Judge of Recorder’s Court, 238 Mich 78, 82; 213 NW 204 (1927), when the 1919 act was adopted by referendum, it necessarily amended [192]*192tho¡¿e portions of the Recorder’s Court act4 with which it was inconsistent. Therefore, if the act of 1919 was validly adopted, then it supersedes MCLA 726.6; MSA 27.3556. If it was not validly adopted, then MCLA 726.6; MSA 27.3556 — providing for state payment of the judges’ salaries — remains applicable to Recorder’s Court.

II.

Plaintiff attacks the assessment of Wayne County residents for payment of part of the salaries of the judges of the Recorder’s Court.5 Plaintiff is a resident taxpayer of Wayne County but not a resident of the City of Detroit. He seeks to relieve similarly situated Wayne County taxpayers of those future assessments the proceeds of which are used to pay the judges’ salaries.

We have concluded that 1919 PA 369 was never constitutionally adopted, that MCLA 726.6; MSA 27.3556 is still in force, and that plaintiff is therefore entitled to the relief requested.

At the time of the passage of the 1919 act and the 1920 referendum held in the City of Detroit to consider its adoption, the Constitution of 1908 governed. Article 5, § 30 of that Constitution provided, in pertinent part, as follows:

"No local or special act * * * shall take effect until approved by a majority of the electors voting thereon in the district to be affected.”6

[193]*193There can be no doubt that 1919 PA 369 is a local act. The Supreme Court of Michigan explicitly so held in Attorney General, ex rel Cotter v Lindsay, 221 Mich 533, 536; 191 NW 826 (1923). That case presented the question whether an amendment to 1919 PA 369 had been properly adopted in the City of Detroit. The amendment, 1921 PA 364, contained no referendum clause and no referendum vote was ever held. The Court invoked art 5, § 30 of the 1908 Constitution and said:

"Whether we consider the object of the act of 1919 as expressed in its title, consider the act in its entirety, or consider the limitations placed on the referendum found in section 7,7 we are irresistably forced to the conclusion that the act is amendatory of local legislation and is local in character.”

In concluding that 1921 PA 364, as an amendment of the act of 1919, was a local act, the Court necessarily decided that the act of 1919 was itself local in character.8

[194]*194It is also clear that Wayne County voters living outside of the City of Detroit did not vote in the April 5, 1920 referendum which resulted in the apparent adoption of 1919 PA 369. Rather, the election was restricted to "the qualified electors” of the City of Detroit in accordance with § 79 of the act.

The question remaining is whether Wayne County residents inhabit a portion of the "district to be affected” by the 1919 act such that they were constitutionally entitled to vote for or against its adoption before it could become effective.

Defendants argue that the City of Detroit is the only "district affected” by the act, because it primarily reorganized and improved the Recorder’s Court for the City of Detroit. This "local court refurbishing”10 is said to affect Wayne County only insignificantly. The only other part of the act — the funding portion — need not be approved by referendum, the argument continues, because the Legislature has the power to order Wayne County taxpayers to pay the salaries of the Recorder’s Court judges. And since the voters of the City of Detroit —the district affected — approved that portion of the act which required a referendum,

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Related

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265 N.W.2d 400 (Michigan Court of Appeals, 1978)

Cite This Page — Counsel Stack

Bluebook (online)
232 N.W.2d 678, 61 Mich. App. 188, 1975 Mich. App. LEXIS 1517, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hart-v-wayne-county-michctapp-1975.