Stephen Censoni v. Citizens Insurance Company of America

CourtMichigan Court of Appeals
DecidedFebruary 14, 2025
Docket368242
StatusUnpublished

This text of Stephen Censoni v. Citizens Insurance Company of America (Stephen Censoni v. Citizens Insurance Company of America) 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
Stephen Censoni v. Citizens Insurance Company of America, (Mich. Ct. App. 2025).

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

STEPHEN CENSONI, UNPUBLISHED February 14, 2025 Plaintiff-Appellant, 3:01 PM

v No. 368242 Oakland Circuit Court CITIZENS INSURANCE COMPANY OF LC No. 2021-187443-NI AMERICA and JOHN DOE,

Defendants, and

GFL ENVIRONMENTAL, INC.,

Defendant-Appellee.

Before: YOUNG, P.J., and GARRETT and WALLACE, JJ.

PER CURIAM.

Plaintiff appeals as of right the trial court’s order granting summary disposition to defendant GFL Environmental, Inc. (“GFL”). Because defendant John Doe (“Doe”) was dismissed without prejudice under MCR 2.102(E)(1), the dismissal did not operate as an adjudication on the merits, and plaintiff is not precluded from maintaining his claims against GFL premised on Doe’s alleged negligence. We therefore reverse and remand for further proceedings.

I. FACTS AND PROCEDURAL HISTORY

Plaintiff was injured when the arm of a garbage truck struck him below his neck as he attempted to pick up a bottle in the roadway. GFL owned the truck, and Doe drove the truck at the time of the incident. Plaintiff filed a complaint against GFL and Doe, alleging that he suffered

-1- accidental bodily injury within the meaning of the no-fault act, MCL 500.3101 et seq.,1 as a result of their negligence.

GFL moved to dismiss Doe under MCR 2.102(E) (dismissal as to defendant not served) and MCL 600.5805 (statute of limitations). GFL asserted that Doe was never served with process because he was never identified and the summons expired. GFL maintained that MCR 2.102(E)(1) required the court clerk to dismiss Doe from this action. GFL also argued that Doe should be dismissed on the basis of the statute of limitations, which had expired. The trial court granted the motion, but did not specify its reasoning.

Thereafter, GFL moved for summary disposition under MCR 2.116(C)(8) (failure to state a claim on which relief can be granted) and (C)(10) (no genuine issue of material fact). GFL argued that plaintiff alleged in his complaint that GFL and Doe negligently operated the truck, but only Doe, and not GFL, could have operated the truck. GFL asserted that plaintiff could not maintain his suit because he failed to plead a claim that allowed GFL to be held liable for Doe’s actions. GFL also argued that all other parties had been dismissed, and the statute of limitations had expired. The trial court granted the motion, but allowed plaintiff 14 days to amend his complaint. Plaintiff filed an amended complaint alleging that (1) GFL was vicariously liable under respondeat superior for Doe’s negligent operation of the truck, and (2) GFL negligently entrusted the truck to Doe.

In lieu of answering the amended complaint, GFL again moved for summary disposition under MCR 2.116(C)(8) and (C)(10). GFL argued that plaintiff could not establish the requisite relationship between GFL and Doe to prove vicarious liability or negligent entrustment because Doe had been dismissed from the action. GFL relied on Al-Shimmari v Detroit Med Ctr, 477 Mich 280, 284-286; 731 NW2d 29 (2007), in which a doctor that the Detroit Medical Center employed had been dismissed from a negligence lawsuit with prejudice because he was served after the statute of limitations expired. Our Supreme Court held that because the dismissal operated as an adjudication on the merits under MCR 2.504(B)(3) (involuntary dismissal), the plaintiff could not argue the merits of his negligence claim against the doctor and was therefore unable to establish that the Detroit Medical Center was vicariously liable for the doctor’s alleged negligence. Id. at 295-296. In this case, GFL argued that Doe’s dismissal rendered plaintiff unable to argue the merits of his claim against GFL because the dismissal operated as an adjudication on the merits and the statute of limitations had expired.

Plaintiff opposed GFL’s motion, arguing that he was able to establish the necessary relationship between GFL and Doe to prove vicarious liability and negligent entrustment. Plaintiff distinguished Al-Shimmari from this action on the basis that the plaintiff in Al-Shimmari knew the doctor’s identity to properly serve him, but, in this case, plaintiff did not know Doe’s identity. Plaintiff argued that GFL should not be able to avoid liability because Doe’s identity was unknown. GFL filed a reply, reiterating its argument that without a finding of negligence attributed to a

1 Plaintiff also named as a defendant his insurer, Citizens Insurance Company of America (“Citizens”), alleging that Citizens breached its insurance contract with plaintiff by refusing to pay benefits. Citizens was dismissed in the trial court and is not a party to this appeal.

-2- known employee of GFL, plaintiff could not establish vicarious liability or negligent entrustment against GFL.

The trial court granted GFL’s motion. Relying on Al-Shimmari, the court recognized that a dismissal on statute-of-limitations grounds operates as an adjudication on the merits. The court determined that plaintiff’s vicarious-liability and negligent-entrustment claims required a finding that Doe was negligent, but because Doe’s dismissal on statute-of-limitations grounds prevented plaintiff from arguing the merits of Doe’s alleged negligence, plaintiff could not establish his claims against GFL. This appeal followed.

II. ANALYSIS

Plaintiff contends that the trial court erred by determining that Doe’s dismissal was with prejudice. He also argues that the trial court erred by granting summary disposition to GFL because Doe’s dismissal was not an adjudication on the merits that barred plaintiff from maintaining his claims against GFL. We agree.

A. STANDARD OF REVIEW

“We review de novo a trial court’s decision on a motion for summary disposition.” El- Khalil v Oakwood Healthcare, Inc, 504 Mich 152, 160; 934 NW2d 665 (2019). Under the de- novo standard, we review the legal issues presented independently, with no deference to the trial court. Bowman v Walker, 340 Mich App 420, 425; 986 NW2d 419 (2022). GFL moved for summary disposition under both MCR 2.116(C)(8) and (C)(10). Because the trial court did not rely on matters outside the pleadings, we analyze the issues under MCR 2.116(C)(8). See Tripp v Baker, 346 Mich App 257, 272; 12 NW3d 45 (2023).

A motion under MCR 2.116(C)(8) tests the legal sufficiency of a claim based on the factual allegations in the complaint. When considering such a motion, a trial court must accept all factual allegations as true, deciding the motion on the pleadings alone. A motion under MCR 2.116(C)(8) may only be granted when a claim is so clearly unenforceable that no factual development could possibly justify recovery. [El-Khalil, 504 Mich at 160 (emphasis, quotation marks, and citations omitted).]

We also “review de novo issues involving the proper interpretation and application of statutes and court rules.” McGregor v Jones, 346 Mich App 97, 100; 11 NW3d 597 (2023). If the language is clear and unambiguous, we interpret the text as written and judicial construction is not permitted. Id.

B. APPLICATION

GFL moved to dismiss Doe under MCR 2.102(E) (dismissal as to defendant not served) and MCL 600.5805 (three-year statute of limitations). MCR 2.102(E)(1) states: “On the expiration of the summons as provided in subrule (D), the action is deemed dismissed without prejudice as to a defendant who has not been served with process . . . .” MCR 2.102(D) provides that a summons expires 91 days after it is issued. Doe’s summons expired on July 15, 2021, before

-3- plaintiff could identify and serve Doe.

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Related

Al-Shimmari v. Detroit Medical Center
731 N.W.2d 29 (Michigan Supreme Court, 2007)
Hyslop v. Wojjusik
652 N.W.2d 517 (Michigan Court of Appeals, 2002)
Durfy v. Kellogg
483 N.W.2d 664 (Michigan Court of Appeals, 1992)
Grimmer v. Lee
872 N.W.2d 725 (Michigan Court of Appeals, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Stephen Censoni v. Citizens Insurance Company of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stephen-censoni-v-citizens-insurance-company-of-america-michctapp-2025.