Kaylee Smarr v. Mary Talaska and County of Alpena

CourtDistrict Court, E.D. Michigan
DecidedJanuary 8, 2026
Docket1:25-cv-12588
StatusUnknown

This text of Kaylee Smarr v. Mary Talaska and County of Alpena (Kaylee Smarr v. Mary Talaska and County of Alpena) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kaylee Smarr v. Mary Talaska and County of Alpena, (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN NORTHERN DIVISION

KAYLEE SMARR

Plaintiff, Case No. 1:25-cv-12588

v. Honorable Thomas L. Ludington United States District Judge MARY TALASKA and COUNTY OF ALPENA

Defendant. _______________________________________/ OPINION AND ORDER GRANTING DEFENDANT ALPENA COUNTY’S MOTION TO DISMISS, DISMISSING ALPENA COUNTY AND REMANDING REMAINING CLAIMS TO ALPENA COUNTY CIRCUIT COURT On August 19, 2025, Defendants removed this case from the Alpena County Circuit Court to this Court. Plaintiff Kaylee Smarr purchased real estate property located in Alpena, Michigan, from the Defendant, Ms. Mary Talaska, in September of 2020. Ms. Talaska financed the sale through a land contract. Despite the volume of pleadings and exhibits provided by the Parties, a copy of the land contract is not included. Importantly, however, the Parties’ filings reflect that the land contract was recorded at the Alpena County Register of Deeds at Liber 537, Page 446. Sometime in the fall of 2022, Ms. Talaska initiated forfeiture proceedings in the 88th District Court in Alpena, Michigan, alleging that Smarr defaulted on her obligations under the land contract. On October 19, 2022, the District Court entered a Judgment of Possession after Land Contract Forfeiture (the “Judgment”). The Judgment—entered with the consent of the Parties— provided that (1) the land contract was forfeited, (2) Talaska was entitled to a money judgment for $1,431.67 to be paid within ninety days with an additional $1,413.03 to be paid within thirty days, (3) Smarr, as a condition of “cure,” was to prospectively pay $750.89 per month and the property taxes when due. Ultimately, the state court was informed by Ms. Talaska or her attorney that Smarr had not performed the conditions of cure, and an order was entered evicting her from the property. But Ms. Talaska’s conduct is not before the Court today. Instead, this Court must determine whether Defendant Alpena County may be liable under Monell v. Dep’t of Soc. Servs. of City of

New York, 436 U.S. 658 (1978), to Plaintiff for her wrongful forfeiture to Talaska and her eviction. Plaintiff contends that Defendant County of Alpena violated her Fourteenth Amendment procedural due process rights when the state district court located in Alpena County deprived her of the property interest in her home without notice or a hearing. While Ms. Talaska’s conduct may have deprived the Plaintiff of her due process and statutory rights, Plaintiff has not pleaded facts that would render Defendant Alpena County liable under Monell. Defendant Alpena County’s Motion to Dismiss will thus be granted. And because the Motion to Dismiss will be granted, the only remaining claims are state-law claims. This Court will decline to exercise supplemental jurisdiction over those remaining claims and remand the case to state court. I.

A. An overview of “land contracts” and Michigan law governing forfeiture in the event of default is necessary to understand Plaintiff’s Complaint. First, a land contract is a contract for the sale of an interest in real estate. 1 JOHN G. CAMERON JR., Michigan Real Property Law, Principles and Commentary 602 (3d ed. 2005). Land contracts include provisions for the sale of an interest in real estate that require payment of the purchase price in installments. Id. There is no promissory note or mortgage involved between the seller (referred to as the vendor) and the buyer (referred to as the vendee). Id. In land contracts, the purchase price is financed by the seller, and legal title remains with the vendor until the buyer performs all contract obligations, while equitable title passes to the vendee. Id. If a vendee fails to pay or timely perform their obligations, “the vendor of a land contract giving the vendee a right to possession may not forfeit the contract on a basis of the default itself.” Id. at 620. Instead, the vendor must seek a declaration of forfeiture from a state district court. Id. A notice of forfeiture must then be served separately to all parties to the contract. Id. Once a notice

of forfeiture is served, the vendee’s right to enforce the contract is terminated, or at least suspended until the contract default is cured by payment of the arrearage. Id. But before all that, there must be notice to the vendee of an intent to forfeit and an opportunity to cure the default, which must initially be determined from the parties’ contract.1 Id. The Summary Proceedings Act requires a cure period of at least fifteen days following service of a forfeiture notice under MICH. COMP. LAWS § 600.5728. Id. at 621. But if not cured, a land contract vendor may seek to forfeit the vendee’s interest in a land contract and retake possession of the property in satisfaction of the debt.2 Id. at 622. In doing so, the vendor will generally seek forfeiture of the contract and possession of the property under MICH. COMP. LAWS § 600.5701. Id. The vendor may recover property following a forfeiture, but only if

the contract expressly gives the vendor the right to declare a forfeiture for a material breach. MICH. COMP. LAWS § 600.5726. Proceedings in district court must comply with MCR 4.202.3 CAMERON, Michigan Real Property Law, Principles and Commentary 622. But a vendor may not recover possession under § 600.5726 unless the vendee —or whoever holds possession under the vendee—has been served with written notice of forfeiture and has failed

1 Absent a contractual requirement, no notice of intent to forfeit is required. See CAMERON, Michigan Real Property Law, Principles and Commentary 621. 2 Contrast the forfeiture proceeding with that of foreclosure, which the vendor might utilize to enforce the vendee’s obligation to pay the full purchase price outlined in the land contract. See CAMERON, Michigan Real Property Law, Principles and Commentary 628–34. 3 This includes MCR 4.202(K)(2), which is at issue in this case. to cure the default. Id. The notice may be served by delivering it personally to the vendee, by delivering it at the premises to a member of the vendee’s family or household or an employee of suitable age and discretion with a request that it be delivered to the vendee, or by sending it to the last known address of the vendee or person holding possession under the vendee by first-class

mail. Id. at 623. After service of the notice of forfeiture and the passage of the requisite cure period, the proceeding may be commenced to recover possession of the property. Id. B. With that in mind, the Court moves sequentially to the next series of events. As earlier noted, the Judgment provided that Plaintiff was to pay Ms. Talaska $1,413.03, within thirty days to reimburse her, and pay a total amount of $1,431.67 within ninety days of the Judgement. ECF No. 1 at PageID.11. The Judgment further ordered Plaintiff to pay Ms. Talaska an additional $750.89 per month beginning in October 2022, and to pay property taxes when due. Id. at PageID.25. On February 21, 2023, through an Application and Order of Eviction filed with the district court, Ms. Talaska, or someone on her behalf, represented that Plaintiff had not complied with the

Judgment by: (1) not paying her past due amount of $1,431.67,4 and (2) by cancelling her homeowner’s insurance.5 Id. at PageID.29. But Plaintiff maintains that she not only paid the required $1,413.03 within 30 days as required by the Judgment, but she also paid the $750.89 every month from October 2022 through March 2023 via direct deposit to Ms. Talaska. Id. at PageID.12. She also asserts that the property was properly insured for the entirety of the required

4 Seemingly, the Application for Eviction notes that Plaintiff had paid a sum of $1,413.03. See ECF No. 1 at PageID.29.

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Kaylee Smarr v. Mary Talaska and County of Alpena, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kaylee-smarr-v-mary-talaska-and-county-of-alpena-mied-2026.