House Speaker v. Governor

491 N.W.2d 832, 195 Mich. App. 376
CourtMichigan Court of Appeals
DecidedAugust 3, 1992
DocketDocket 148677, 148678, 148679
StatusPublished
Cited by8 cases

This text of 491 N.W.2d 832 (House Speaker v. Governor) 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
House Speaker v. Governor, 491 N.W.2d 832, 195 Mich. App. 376 (Mich. Ct. App. 1992).

Opinions

Marilyn Kelly, J.

BACKGROUND AND ISSUES ON APPEAL

Defendants appeal as of right from an order of the Ingham Circuit Court which granted summary disposition to plaintiffs and enjoined defendants [380]*380from implementing Executive Order 1991-31. They argue on appeal that plaintiffs lacked standing and that the claims are nonjusticiable political questions. They assert that the Governor is absolutely immune from suit and that his executive order was a valid exercise of authority granted him by the Michigan Constitution. Plaintiffs Michigan Environmental Protection Foundation et al. (mepf) cross appeal, arguing that the trial court erred in denying them attorney fees and costs and in failing to find a second executive order, EO 1991-33, unconstitutional.

EO 1991-31 alters the state’s role with respect to its natural resources by expressly abolishing the existing Department of Natural Resources (dnr) and creating a new one. The trial court characterized the order as an attempt to accomplish the most comprehensive reorganization of state government since the implementation of the 1963 constitution. A second order, EO 1991-33, creates an Environmental Science Board to advise the Governor on environmental issues.

The circuit court ruled that all the plaintiffs had standing. It then found that EO 1991-31 violated the separation of powers clause of the Michigan Constitution. Const 1963, art 3, § 2. In addition, it determined that, in issuing EO 1991-31, the Governor exceeded his authority under both the Michigan Constitution and the Executive Organization Act, MCL 16.101 et seq.; MSA 3.29(1) et seq. It found the Governor lacked authority to appoint the head of the Natural Resources Commission (nrc). It ruled he was not empowered to abolish commissions and boards whose functions include the holding of public hearings. The court concluded by ruling that EO 1991-31 was not violative of the Open Meetings Act, MCL 15.261 et seq.; MSA 4.1800(11) et seq., Freedom of Information [381]*381Act, MCL 15.231 et seq.; MSA 4.1801(1) et seq., Revised Judicature Act, MCL 600.101 et seq.; MSA 27A.101 et seq., or substantive due process. The court refused to award attorney fees on the basis that a public question was involved.1

We affirm the actions of the circuit court.

THE PLAINTIFFS HAVE STANDING

Defendants argue initially that plaintiffs lacked standing to bring this action. The requirement of standing ensures that only those who have a substantial interest in a dispute will be allowed to come into court to be heard. House Speaker v State Administrative Bd, 190 Mich App 260, 265; 475 NW2d 440 (1991), lv gtd 439 Mich 1013 (1992), citing Highland Recreation Defense Foundation v Natural Resources Comm, 180 Mich App 324, 328; 446 NW2d 895 (1989). Plaintiffs must show both a substantial interest in the dispute and that they will be detrimentally affected by the litigation in a manner different than the citizenry at large. House Speaker, 266, citing Muskegon Building & Construction Trades v Muskegon Area Intermediate School Dist, 130 Mich App 420, 423-424; 343 NW2d 579 (1983).

In House Speaker, certain legislators brought suit claiming that the state administrative board’s transfer of funds within various state departments exceeded the board’s statutory authority and violated the state constitution. They asserted that the intertransfers could be accomplished only by the state budget director, subject to review by legislative appropriations committees. Alternatively, they argued that, if the Management and Budget Act, [382]*382MCL 18.1101 et seq.; MSA 3.516(101) et seq., authorized the transfers, the act was unconstitutional, as it delegated legislative power to the executive branch of state government. This Court determined that, under either theory, the legislators, members of the appropriations committees or their appointors, clearly asserted substantial interests different in kind from those of the citizenry at large. Id., 266-267.

As in House Speaker, the legislator plaintiffs here argue that the Governor violated the separation of powers clause by exceeding the scope of legislative power which Michigan’s constitution grants him. Const 1963, art 5, § 2. The legislator plaintiffs are: Lewis Dodak, Speaker of the Michigan House of Representatives; Thomas Alley, Chair of the House Committee on Conservation, Recreation and the Environment; Tracey Yokich, member of the House Committee on Conservation, Recreation and the Environment; John D. Cherry, the Senate Minority Floor Leader; and Arthur Miller, the Senate Minority Leader.

The Michigan Legislature is constitutionally mandated to protect the natural resources of this state from pollution, impairment and destruction. The executive order challenged eliminates a substantial number of boards and commissions which the Legislature created for the purpose of protecting the environment. See Const 1963, art 4, § 52. We agree with the trial court that the legislator plaintiffs clearly have asserted substantial interests as legislators different in kind from those of the citizenry at large. House Speaker, 267.

Plaintiffs Michigan United Conservation Clubs et al. (mucc) and mepf also unquestionably had standing to bring this action and to obtain the relief sought and granted. The trial court ruled that their standing was based on their status as [383]*383taxpayers. MCR 2.201(B)(4). Mucc and mepf are nonprofit corporations, organized for civic, protective or improvement purposes. They and five or more of their members, who own property assessed for direct taxation by the county in which they reside, filed this action. MCR 2.201(B)(4)(a) and (b). In concert with the legislator plaintiffs, these plaintiffs alleged that the executive order exceeded the Governor’s authority and that any expenditure of funds by a new dnr would be illegal. MCR 2.201(B)(4).

The standing of mucc and mepf may be based, also, on their status as nonprofit corporations which were incorporated to establish and protect the rights and interests of their members. See Muskegon Building Trades, 428. Individual plaintiffs are members of mucc or mepf and either are also members of, or regularly attend and speak at meetings of, boards and commissions to be abolished under EO 1991-31. These plaintiffs clearly have a substantial interest different in kind from the citizenry at large. See Muskegon Building Trades, supra.

nonjusticiable political questions are not INVOLVED

Defendants next assert that the trial court should have used its "equitable discretion” and dismissed this case, because the matters at issue are nonjusticiable political questions. They point out that the doctrine of equitable discretion should be applied, since the Legislature may: 1) elect to reject the two contested executive orders by mustering a majority vote of both the House and Senate; 2) overturn the orders through subsequent legislation; and 3) reduce the orders’ effectiveness through the appropriations process.

[384]*384The federal doctrine of equitable discretion has been applied "where a congressional plaintiff could obtain substantial relief from his fellow legislators through the enactment, repeal, or amendment of a statute.” House Speaker, 270, citing

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Bluebook (online)
491 N.W.2d 832, 195 Mich. App. 376, Counsel Stack Legal Research, https://law.counselstack.com/opinion/house-speaker-v-governor-michctapp-1992.