Matthew Nicholas v. Aaron Michael Wilson

CourtMichigan Court of Appeals
DecidedJune 27, 2024
Docket364242
StatusUnpublished

This text of Matthew Nicholas v. Aaron Michael Wilson (Matthew Nicholas v. Aaron Michael Wilson) 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
Matthew Nicholas v. Aaron Michael Wilson, (Mich. Ct. App. 2024).

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

MATTHEW NICHOLAS, UNPUBLISHED June 27, 2024 Plaintiff-Appellee,

v No. 364242 Wayne Circuit Court AARON MICHAEL WILSON, LC No. 11-012625-CZ

Defendant-Appellant.

Before: MARKEY, P.J., and SWARTZLE and MARIANI, JJ.

PER CURIAM.

Plaintiff, Matthew Nicholas, sought to renew a tort judgment by ex parte motion a couple months before its 10-year expiration date; however, the trial court did not order the renewal of the judgment until after the 10-year limitations period expired. But the court’s order was entered nunc pro tunc, retroactively taking effect before the tort judgment expired. Defendant, Aaron Michael Wilson, moved to set aside the nunc pro tunc order, and the trial court denied the motion as well as Wilson’s subsequent motion for reconsideration. Wilson appeals by leave granted,1 arguing that the trial court lacked the authority to enter the nunc pro tunc order. We affirm.

I. BACKGROUND

On November 1, 2009, Nicholas and his friends attended a Detroit Lions football game in Detroit. After the game, Wilson threatened to harm Nicholas and then committed a battery against him, which required Nicholas to undergo multiple surgeries and resulted in significant medical expenses. Nicholas filed an assault-and-battery tort action against Wilson, and on April 20, 2012, a default judgment was entered against Wilson for failure to file an answer to the complaint. The total amount of the default judgment was $372,205.19. Nicholas took no further action related to the judgment until February 2022. On February 20, 2022, Nicholas filed an ex parte motion to

1 Nicholas v Wilson, unpublished order of the Court of Appeals, entered May 11, 2023 (Docket No. 364242).

-1- renew the judgment, alleging that he had received no payments on the judgment since its entry in April 2012.

On March 18, 2022, the trial court issued a subpoena, ordering Wilson to appear and produce evidence of his assets. Inexplicably, Nicholas’s ex parte motion to renew the judgment, filed on February 20, 2022, was not entered in the register of actions until April 5, 2022, 15 days before the default judgment was set to expire on April 20, 2022. But even after the motion was entered in the register of actions, the trial court took no action to grant Nicholas’s motion.

On May 12, 2022, Wilson moved to quash the subpoena, contending that the judgment was not timely renewed; therefore, it was no longer enforceable. Accordingly, the subpoena was invalid and unenforceable. The trial court, presumably realizing the error, granted Nicholas’s ex parte motion to renew the judgment on May 23, 2022, nunc pro tunc. The order retroactively took effect on April 5, 2022, the day the ex parte motion had been entered into the register of actions.

Wilson moved to set aside the nunc pro tunc order, or, alternatively, to stay proceedings pending appeal. He argued that the trial court simply lacked the authority to enter the order. Wilson maintained that a nunc pro tunc order may only be used to supply an omission of action previously taken but not recorded, not to supply the omitted action. In response, Nicholas argued that nunc pro tunc was an appropriate mechanism for entry of the trial court’s order and that the court also had the authority to remedy errors arising from its own oversight or omission under MCR 2.612(A)(1) (clerical mistakes). Nicholas contended that he should not be left without a remedy when he submitted the ex parte motion two months before the default judgment expired.

The trial court heard oral arguments on Wilson’s motion on June 17, 2022. The court found that the reasons or bases asserted by Nicholas in response to Wilson’s motion were correct, which necessarily would have included Nicholas’s argument under MCR 2.612(A). The trial court opined that Nicholas had not failed in any respect in his filings. The court concluded that renewing a judgment under MCL 600.2903 is simply a ministerial act. And it explained that it had the authority to effectuate ministerial acts “when they should have occurred.” The trial court believed that giving retroactive effect to its order renewing the judgment would not divest Wilson of his rights; rather, not doing so would result in a divesture of Nicholas’s rights. The court also ruled that MCR 2.613(A) provided it with the authority to retroactively renew the default judgment because failing to do so would result in a substantial injustice. The trial court further stated that Nicholas’s procedural and substantive due process rights would be violated if it did not retroactively renew the judgment. Finally, the court referred to a Supreme Court, COVID-related administrative order extending filing deadlines, suggesting that the administrative order supported its ruling. The trial court entered an order denying Wilson’s motion to set aside the nunc pro tunc order for the reasons stated on the record. The court also denied Wilson’s motion to quash the subpoena because it was now moot. The trial court subsequently denied Wilson’s motion for reconsideration, concluding that it did not make a palpable error. This Court granted Wilson’s application for leave to appeal.

II. ANALYSIS

On appeal, Wilson argues that the trial court erred by entering the nunc pro tunc order because there is no authority for a court to enter such an order under the circumstances presented;

-2- therefore, this Court should reverse the trial court’s order denying Wilson’s motion to set aside the nunc pro tunc order.

A. STANDARD OF REVIEW

“We review de novo whether a judicial decision should apply retroactively, whether a statute of limitations bars a claim, and questions of statutory interpretation.” Farley v Advanced Cardiovascular Health Specialists, PC, 266 Mich App 566, 570-571; 703 NW2d 115 (2005). We also review de novo the interpretation and application of statutes and court rules. In re Sanders, 495 Mich 394, 404; 852 NW2d 524 (2014). “De novo review means that we do not extend any deference to the trial court.” In re Ott, 344 Mich App 723, 735; 2 NW3d 120 (2022). “An exercise of the court’s inherent power may be disturbed only upon a finding that there has been a clear abuse of discretion.” Colen v Colen, 331 Mich App 295, 304; 952 NW2d 558 (2020) (quotation marks and citation omitted). A trial court abuses its discretion when its ruling falls outside the range of reasonable and principled outcomes. Id.

B. DISCUSSION AND RESOLUTION

We initially note that Wilson fails to address and assail the trial court’s reliance on MCR 2.613(A), MCR 2.612(A)(1),2 due-process principles, and a Supreme Court administrative order.3 Regardless whether any of those authorities actually provides valid legal support for the trial court’s ruling, “[w]hen an appellant fails to dispute the basis of a lower court’s ruling, we need not even consider granting the relief being sought by the appellant.” Denhof v Challa, 311 Mich App 499, 521; 876 NW2d 266 (2015). For that reason alone, Wilson’s appeal fails.

“[T]he period of limitations is 10 years for an action founded upon a judgment or decree rendered in a court of record of this state . . . from the time of the rendition of the judgment or decree.” MCL 600.5809(3) (emphasis added). MCL 600.2903 provides:

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Related

Van Reken v. Darden, Neef & Heitsch
674 N.W.2d 731 (Michigan Court of Appeals, 2004)
Farley v. Advanced Cardiovascular Health Specialists, PC
703 N.W.2d 115 (Michigan Court of Appeals, 2005)
Denhof v. Challa
876 N.W.2d 266 (Michigan Court of Appeals, 2015)
Kern v. Washtenaw Circuit Judge
206 N.W. 532 (Michigan Supreme Court, 1925)
In re Sanders
852 N.W.2d 524 (Michigan Supreme Court, 2014)
Washburn v. Michailoff
613 N.W.2d 405 (Michigan Court of Appeals, 2000)

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Bluebook (online)
Matthew Nicholas v. Aaron Michael Wilson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matthew-nicholas-v-aaron-michael-wilson-michctapp-2024.