Michael Pung v. Peter Kopke

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 28, 2025
Docket22-1939
StatusUnpublished

This text of Michael Pung v. Peter Kopke (Michael Pung v. Peter Kopke) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Pung v. Peter Kopke, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0044n.06

Case Nos. 22-1919/1939

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Jan 28, 2025 KELLY L. STEPHENS, Clerk

) MICHAEL PUNG, Personal Representative of ) ON APPEAL FROM THE the Estate of Timothy Scott Pung, ) UNITED STATES DISTRICT Plaintiff - Appellant, ) COURT FOR THE EASTERN ) AND WESTERN DISTRICT OF v. ) MICHIGAN ) PETER M KOPKE, et al., ) OPINION ) Defendants - Appellees. ) )

BEFORE: McKEAGUE, KETHLEDGE, and NALBANDIAN, Circuit Judges.

McKEAGUE, Circuit Judge. A Michigan resident can reduce their property tax burden

by exempting their primary residence from local school district taxes. Timothy Pung’s primary

residence (the “Pung property”) received this exemption for many years. But after he died in 2004,

Isabella County officials denied this exemption, causing an unpaid tax debt which led to the

foreclosure of the property. Michael Pung—the representative of Timothy Pung’s estate—sued

Isabella County and several state officials claiming that the events leading up to the foreclosure

sale and the sale itself violated the Fifth and Eighth Amendments. He also claims that defendants

denied him equal protection and conspired to deprive him of due process. The district court granted

Pung partial summary judgment on his Fifth Amendment claim. But the court either dismissed or

granted summary judgment to the defendants on his other claims. We AFFIRM. Nos. 22-1919/1939, Pung v. Kopke, et al.

I.

A. Factual Background

Michigan law provides that a property owner may claim an exemption from local school

district taxes if the owner occupies the property as his or her principal residence. Mich. Comp.

Laws § 211.7cc(1). This exemption is called the Principal Residence Exemption (PRE), and an

owner can claim it by “filing an affidavit . . . with the local tax collecting unit in which the property

is located.” Id. at § 211.7cc(2). The local tax collecting unit’s assessor determines whether the

property owner is eligible for the PRE. Id. at § 211.7cc(6). If an assessor denies a PRE, they must

provide reasons for the denial in writing to the owner as well as the county treasurer. Id.

This appeal revolves around the Pung property in Union Township, Isabella County,

Michigan. Timothy Pung, who passed away in 2004, previously owned the Pung property.

Appellant Michael Pung (Timothy’s uncle) is the personal representative of the resulting estate.

Timothy filed an affidavit for a PRE in 1994, and the PRE was still active when Timothy died.

Timothy was survived by his wife Donnamarie, and two children Katie and Marc. Upon Timothy’s

passing, Donnamarie continued to live in the residence until her death in 2008. After her death,

Marc continued to reside there.

In March 2010, Appellee Patricia DePriest—the Union Township tax assessor—

retroactively denied the PRE for the Pung property for tax years 2007, 2008, and 2009. DePriest

was unsure who owned the property after Timothy’s death, as “there was no other person on the

deed or on the [PRE] affidavit” and Union Township representatives “could never find anyone at

the address.” DePriest Dep., E.D. R. 18-12, PageID 447. DePriest believed that the law required

any new owner of a residence to file an affidavit to claim the PRE. Because there was no affidavit

from Timothy Pung’s heirs on file, she denied the PRE for those three years. She did not apply the

2 Nos. 22-1919/1939, Pung v. Kopke, et al.

PRE to the property for the 2010 or 2011 tax years. The Pungs appealed DePriest’s denial regarding

the 2007, 2008, and 2009 tax years to the Michigan Tax Tribunal. In the meantime, they refused

to pay the extra taxes related to DePriest’s denial of the PRE for the 2010 and 2011 tax years.

The Pungs successfully challenged DePriest’s retroactive denial in the Michigan Tax

Tribunal. After a hearing, the Tribunal granted the PRE to the Pung property. The Tribunal

explained that Timothy Pung’s estate still owned the property, and that Donnamarie and Marc were

beneficiaries and thus part owners of the estate. Thus, Donnamarie and Marc were not new owners.

The Tribunal also found that Donnamarie and Marc resided continuously at the property after

Timothy’s death. Since a property owner is entitled to the PRE as long as the property is the

owner’s principal residence, the Tribunal held that the Pung property “qualified to receive [a PRE]

under MCL 211.7cc for the tax years at issue.” Tribunal Order, E.D. R. 8-4 PageID 84. During the

hearing the presiding ALJ of the Tribunal said that the Pungs did not need a new affidavit—

expressly rejecting DePriest’s reading of the law. The Tribunal entered the order in March 2012.

Curiously, the written order did not address whether the Pungs had to file a new affidavit to claim

the PRE.

In June 2012, Appellee Steven Pickens—the Isabella County Treasurer—initiated

foreclosure proceedings related to the unpaid balance on the 2010 and 2011 taxes. Despite having

reservations, DePriest complied with the ALJ’s oral representations and granted the 2012 PRE in

December 2012. But DePriest did not let the matter rest. Notwithstanding the ALJ’s statements at

the hearing, she was steadfast in her belief that every subsequent owner of a property was required

to file a new affidavit to claim the PRE. She reached out to Appellee Peter Kopke—former Chief

Clerk of the Michigan Tax Tribunal—who confirmed that she had to deny the PRE for the Pung

property because a new affidavit was never filed.

3 Nos. 22-1919/1939, Pung v. Kopke, et al.

On February 4, 2013, the Pungs moved to dismiss the foreclosure proceeding based on the

tax tribunal’s ruling. On February 7, the County dropped the Pung property from its foreclosure

petition and asked the court to deny as moot the Pungs’ motion to dismiss. On that same day,

DePriest revoked the Pung property’s PRE for the 2012 tax year. On February 15, the circuit court

rejected the County’s mootness arguments and held that the Tax Tribunal’s ruling applied to the

2010 and 2011 tax years and declared the Pungs taxes fully paid. Thus, it dismissed the County’s

foreclosure petition against the Pung property. The Michigan Court of Appeals affirmed that ruling

in 2015.

The record is unclear whether Pung received written notice of the 2012 PRE denial as

required under Michigan law. DePriest claims that she sent a notice letter as a matter of standard

practice; Pung claims that he never received a letter. Pung nevertheless received verbal notice of

the revocation when he was trying to pay his tax bill in late February 2013. Pung immediately

wrote the Tax Tribunal requesting the enforcement of its 2012 order for the years 2010–12. Kopke

refused, stating that the Tax Tribunal order only applied to years 2007–09. Pung wrote again,

reiterating his demand to enforce the Tribunal order. Kopke replied that he could not address

Pung’s demand and Pung should have filed an official appeal with the Tribunal or the Union

Township Board of Review.

Pickens was aware of the controversy surrounding the Pung property. When DePriest

denied the PRE for 2012, which resulted in additional property taxes, Pung’s attorney had asked

Pickens to “abate” the taxes. Since Pickens had no power to do so, he reached out to the Tax

Tribunal to get clarification on the impact of the Tax Tribunal’s order. Pickens also recalls

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