Miles v. Wayne County Treasurer

CourtDistrict Court, E.D. Michigan
DecidedJanuary 31, 2025
Docket2:24-cv-11125
StatusUnknown

This text of Miles v. Wayne County Treasurer (Miles v. Wayne County Treasurer) 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
Miles v. Wayne County Treasurer, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION CHARLES MILES, 2:24-CV-11125-TGB-KGA Plaintiff, HON. TERRENCE G. BERG vs. ORDER GRANTING WAYNE COUNTY TREASURER DEFENDANT CITY and CITY OF DETROIT OF DETROIT’S TREASURER OFFICE, MOTION TO DISMISS Defendants. (ECF NO. 5)

AND GRANTING DEFENDANT WAYNE COUNTY TREASURER’S MOTION TO DISMISS (ECF NO. 8) Plaintiff Charles Miles, proceeding pro se, brings this action against the Wayne County Treasurer and the City of Detroit Treasurer challenging property tax bills he has been issued on two properties he owns in the City of Detroit for tax years 2016, 2017, 2018, and 2021. His objections stem from the Michigan Treasury Department’s 2016 denial of a “Principal Residence Exemption” (“PRE”) for one of his properties and the retroactive adjustment and increase in his property tax bill for prior years. Miles alleges that as a result of the assessment and attempted collection of real property taxes, his properties “are currently in property tax foreclosure by the Wayne County Treasurer’s office” and he seeks an injunction “to stop the arbitrary tax foreclosure” of his properties, as well

as monetary damages for Defendants’ alleged unlawful actions. Now before the Court are Defendants City of Detroit’s and Wayne County Treasurer’s Motions to Dismiss Plaintiff’s Complaint Pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6). ECF Nos. 5 and 8. Defendants argue that the Complaint should be dismissed because the Tax Injunction Act and principles of comity deprive this Court of jurisdiction over claims like Plaintiff’s—challenging the assessment and collection of state property taxes. Pursuant to Eastern District of Michigan Local Rule 7.1(f)(2), the

motions will be decided without oral argument. For the reasons set forth below, the Court will GRANT both the City of Detroit’s and Wayne County Treasurer’s Motions to Dismiss. I. BACKGROUND A. Factual Background Plaintiff Charles Miles alleges that he is the owner of three properties in the City of Detroit: (1) 9550 Hubbell; (2) 6463 Evergreen; and (3) 12900 Santa Clara. Complaint ¶ 7, ECF No. 1, PageID.2. Miles alleges that he had a “principal residence exemption” (“PRE”) for the

property located at 9550 Hubbell from 2009 to 2013, and that he transferred the PRE to his new home at 12900 Santa Clara in 2013. Id. ¶¶ 17–18. However, Miles says that the PRE was not rescinded on the

9550 Hubbell property. Id.1 Michigan’s PRE is governed by §§ 7cc and 7dd of the General Property Tax Act (“GPTA”), MCL §§ 211.7cc and 211.7dd. A PRE exempts a principal residence “from the tax levied by a local school district for school operating purposes to the extent provided under ... [MCL §] 380.1211, if an owner of that principal residence claims an exemption as provided in this section.” See MCL § 211.7cc(1) (emphasis added). In order to qualify for the PRE in real property, the person claiming the

exemption must own that property; occupy the property as a principal residence; and file an affidavit “on a form prescribed by the department of treasury” “stat[ing] that the property is owned and occupied as a principal residence by that owner of the property on the date that the affidavit is signed.” MCL § 211.7cc(2). The Act provides for rescission of a claim for a PRE “by filing with the local tax collecting unit a rescission form prescribed by the department of treasury.” MCL 211.7cc(5). The Act also authorizes the County to audit claimed exemptions. MCL 211.7cc(10). If the County denies a claimed PRE, the County treasurer

issues a corrected tax bill including interest. MCL § 211.7cc(11).

1 Miles only specifically discusses the 9550 Hubbell property in his Complaint and fails to discuss any details of the 6463 Evergreen property in the body of his Complaint. See ECF No. 1. The Michigan State Treasurer conducted an audit of Miles’s

claimed exemptions in 2016, and then denied a PRE for the Hubbell property for the years 2013, 2014, 2015, and 2016. ECF No. 1, ¶ 18. When the taxes were not paid in full, the taxes were transferred to the Wayne County Treasurer as a delinquent debt. Id. ¶ 19. Miles requested an informal conference with the State to contest the PRE denials, and this request was denied as untimely on April 26, 2019. ECF No. 5-4. The denial informed Miles that he could appeal that decision to the small claims division of the Michigan Tax Tribunal

(“MTT”). Id. Miles then attempted to appeal to the MTT. That appeal was subsequently dismissed in a decision dated August 29, 2019 because Miles “did not submit a copy of the notice giving rise to the appeal,” he was “placed in default on July 3, 2019,” he “has made no attempt to cure the default,” and his “failure to comply with two Orders has established a history of deliberate delay.” ECF No. 5-5, PageID.184. That decision stated that Miles could file a motion for reconsideration with the MTT or a claim of appeal with the Michigan Court of Appeals. Id. PageID.185. Miles does not allege that he pursued either route of possible appeal.

As a result of the cancellation of the PRE for the Hubbell property for 2013 through 2016, Miles’s tax bills, starting with his 2016 tax bill, were retroactively adjusted upward to include the additional taxes he should have been charged and paid. ECF No. 1, ¶¶ 18–20; see also Emails, ECF No. 5-6. Miles has since disputed the adjusted tax bills, contending that he was unjustly or incorrectly assessed interest, fees, and penalties

and disputing the back fees owed for the PRE rescission. ECF No. 1, ¶¶ 21–27 (complaining that he “had no idea how much was actually discounted under the PRE for 2013, 2014, and 2015” and “no idea how to is [sic] verify what is actually owed to the Detroit City Treasurer Office.”). Miles and the City of Detroit exchanged a number of emails through April 4, 2024, discussing the property taxes for the 9550 Hubbell and 6463 Evergreen properties, with the City explaining why the taxes were delinquent and in what amounts. ECF No. 5-6, PageID.190–216. The City

attached the tax liability statements for each property to the emails and advised Miles that he needed to either make full payments or set up a payment plan through Wayne County. Id. Miles instead filed the instant action. B. Procedural History On April 29, 2024, Miles then filed this action against both the City of Detroit Treasurer’s Office and the Wayne County Treasurer. ECF No. 1. Miles alleges a denial of due process under the Fourteenth Amendment because the City “charge[ed] [Miles] back fees from 2013, 2014, and the

2015 PRE tax discount; without ever telling [him] what the actual discounts were during those years,” and then forwarded the debt to the Wayne County Treasurer before sending it to Miles, thereby incurring extra fees and penalties. Id. Claims for Relief, ¶¶ 4–5. He requests that the Court “issue an injunction to stop the arbitrary tax foreclosure of [his] properties,” “inform all resident(s) receiving PRE … the exact amount

discounted each year the resident receive[s] the discount,” and “[a]ward [him] cots[s], and fees deem[ed] proper by the court for 7 years of emotional stress based on [Defendants’] arbitrary practices.” Id. Prayers for Relief, ¶¶ 6-8. On May 23, 2024, Defendant City of Detroit filed a Motion to Dismiss Plaintiff’s Complaint pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6). ECF No. 5. The City argued that Miles’s claims contesting the assessment and collection of real property taxes on his properties are

barred by the Tax Injunction Act (“TIA”), 28 U.S.C. § 1341

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Miles v. Wayne County Treasurer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miles-v-wayne-county-treasurer-mied-2025.