Jennifer Janssen-Rogers v. Dept of Environment Great Lakes and Ene

CourtMichigan Court of Appeals
DecidedJanuary 29, 2026
Docket369025
StatusUnpublished

This text of Jennifer Janssen-Rogers v. Dept of Environment Great Lakes and Ene (Jennifer Janssen-Rogers v. Dept of Environment Great Lakes and Ene) 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
Jennifer Janssen-Rogers v. Dept of Environment Great Lakes and Ene, (Mich. Ct. App. 2026).

Opinions

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

JENNIFER JANSSEN-ROGERS, and BROOKE UNPUBLISHED ROSENBAUM, January 29, 2026 9:20 AM Plaintiffs-Appellees,

V No. 369025 Court of Claims DEPARTMENT OF ENVIRONMENT, GREAT LC No. 21-000246-MM LAKES, AND ENERGY, and ERIC OSWALD,

Defendants-Appellants.

DARETHA BRAZIEL, Individually and as Next Friend of RB, DB, and DR, Minors, KEESHA JONES, Individually and as Next Friend of KJ, DJ, TMC, TC, and KB, Minors, IEASHA JONES, MICHAEL D. BRIGHAM, REBECCA BRANSCUMB, STACEY BRANSCUMB, and EMMA KINNARD,

Plaintiffs-Appellees,

V No. 369026 Court of Claims DEPARTMENT OF ENVIRONMENT, GREAT LC No. 22-000046-MM LAKES, AND ENERGY, ERIC OSWALD, DEPARTMENT OF HEALTH AND HUMAN SERVICES, and DIRECTOR OF DEPARTMENT OF HEALTH AND HUMAN SERVICES,

OLIVER KAVANAUGH, Individually and as Next Friend of KNR, Minor,

-1- Plaintiffs-Appellees,

V No. 369027 Court of Claims DEPARTMENT OF ENVIRONMENT, GREAT LC No. 22-000050-MM LAKES, AND ENERGY, and ERIC OSWALD,

Before: KOROBKIN, P.J., and MURRAY and MALDONADO, JJ.

PER CURIAM.

These consolidated putative class-action appeals arose from high levels of lead in the tap water in Benton Harbor (the City). Defendants appeal by leave granted 1 the opinion and order of the Court of Claims denying defendants’ motion for summary disposition under MCR 2.116(C)(7) (statute of limitations). Plaintiffs are City residents and business owners who brought claims for personal injury and property damages resulting from lead in the municipal water. Defendants argue that the Court of Claims failed to apply the correct standards for deciding motions under MCR 2.116(C)(7). Defendants also argue that plaintiffs failed to file their complaints or notice of intent to sue within six months of accrual of their claims, as required under the Revised Judicature Act, 600.101 et seq. We disagree and affirm.

I. BACKGROUND

Under the Safe Drinking Water Act, MCL 325.1001 et seq., the Department of Environment, Great Lakes, and Energy (EGLE)2 is responsible for the promulgation of rules setting water-quality standards and establishing requirements for the safe operation of water systems. MCL 325.1005. EGLE has promulgated a set of administrative rules known collectively as the Lead and Copper Rule (LCR). See Mich Admin Code, R 325.10401a; Mich Admin Code, R 325.10410; Mich Admin Code, R 325.10604f; Mich Admin Code, R 325.10710a; Mich Admin Code, R 325.10710b; Mich Admin Code, R 325.10710c; Mich Admin Code, R 325.10710d.

Rule 325.10604f(6) requires water suppliers to remove lead service lines from their systems over time. Rule 325.10710a(4) requires suppliers to monitor their systems for lead by collecting samples from consumers over six-month periods. The LCR specifies “action levels” of

1 Janssen-Rogers v EGLE, unpublished order of the Court of Appeals, entered June 12, 2024 (Docket No. 369025); Braziel v EGLE, unpublished order of the Court of Appeals, entered June 12, 2024 (Docket No. 369026); Kavanaugh v EGLE, unpublished order of the Court of Appeals, entered June 12, 2024 (Docket No. 369027). 2 The former Department of Environmental Quality was reorganized and renamed as EGLE in 2019. Some of the events involved in this case occurred before this name change, but, for con- venience, we consistently use “EGLE.”

-2- lead concentration to protect the public in the event of excessive leaching of lead from pipes and fixtures into drinking water. Mich Admin Code, R 325.10401a; Mich Admin Code, R 325.10604f(2)(e)(i); Mich Admin Code, R 325.10604f(5). If an “action-level exceedance” (ALE) occurs, the LCR requires the water supplier—the City in the present cases—to take certain actions to protect the public, including public education, changing the treatment protocol, and expediting the replacement of lead service lines. Mich Admin Code, R 325.10401a; Mich Admin Code, R 325.10604f(2)(e)(i); Mich Admin Code, R 325.10604f(5). Through December 31, 2024, an action level for lead was considered to be reached when 10% of the samples collected from consumer taps were at or above 0.015 milligrams per liter, or 15 parts per billion (ppb). Mich Admin Code, R 325.10604f(1)(c); Mich Admin Code, R 325.10401a, Table 1.

During the summer of 2018, the City collected residential water samples that had a 90th percentile of 22 ppb, thus constituting an ALE for the City’s water system. In October 2018, EGLE sent the City notice of the ALE and detailed the actions required of the City in response, including distributions of a public advisory and educational materials, and proposing a corrosion- control treatment plan or study.

Eight days later, the City distributed a public advisory letter to all of the addresses in the water system with information about the ALE, resources for further information, and a list of best practices to “reduce your risk of lead exposure,” including the following: • Run your water to stable, cold temperatures (usually 3 to 5 minutes) before drinking to flush out any potential contaminants.

• Use cold water tap for drinking or cooking.

• Use bottled water to prepare baby formula.

The City also distributed the public advisory to the media and held a press conference. A month later, the City mailed educational materials to water-system customers, which included the following “steps you can take to reduce your exposure to lead in your water”: 1. Run your water to flush out lead. . . .

2. Use cold water for cooking and preparing baby formula. . . .

* * *

4. Look for alternative sources or treatment of water. You may want to consider purchasing bottled water or a water filter. . . .

A January 2019 EGLE internal memorandum indicated that EGLE was aware that the City was “not following through on their original public commitments . . . to provide bottled water or filters to residents with high lead results.” At a town hall meeting later that month, the Department of Health and Human Services (DHHS) announced that water filters would be available for the City’s water customers to pick up.

-3- The City hired a consulting engineering company to help with corrosion control, which recommended Carus 8600, a phosphate-based corrosion inhibitor. EGLE approved the treatment and issued the City a permit to implement it. The City began doing so in March 2019. During the same month, the City entered into an administrative consent order with EGLE to address several issues with the management of the system, many unrelated to the ALE.

The results from the residential water samples that the City collected during the first and second halves of 2019 again constituted ALEs. In response, the City distributed public advisories and educational materials with lists of recommendations for reducing the risk of lead exposure. The recommendations varied slightly with each publication, but collectively included using filters in households with children and pregnant women; using bottled water; flushing pipes “at least five minutes” before drinking the water; using only cold water for drinking, cooking, or preparing baby formula; considering the purchase of bottled water; cleaning faucet aerators every six months; identifying older plumbing fixtures; testing children for lead exposure; and testing household water for lead. After the third ALE occurrence, EGLE designated a new treatment protocol for the City on the basis of a third-party consultant’s recommendation, exercising its broad authority under MCL 325.1015(1), Rule 325.10604f(2)(c), and Rule 325.10604f(3)(h).

The City’s residential water sampling during 2020 and the first half of 2021 produced a fourth, fifth, and sixth ALE.

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Jennifer Janssen-Rogers v. Dept of Environment Great Lakes and Ene, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jennifer-janssen-rogers-v-dept-of-environment-great-lakes-and-ene-michctapp-2026.