Thomson v. Peterson

CourtDistrict Court, E.D. Michigan
DecidedSeptember 30, 2025
Docket1:24-cv-11761
StatusUnknown

This text of Thomson v. Peterson (Thomson v. Peterson) 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
Thomson v. Peterson, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN NORTHERN DIVISION

CAMERON THOMSON,

Plaintiffs, Case No. 1:24-cv-11761

v. Honorable Thomas L. Ludington United States District Judge SAMANTHA PETERSON,

Defendants. _________________________________________/

OPINION AND ORDER (1) GRANTING IN PART PLAINTIFF’S MOTION TO STRIKE OR EXCLUDE AFFIDAVIT AND MATERIALS OUTSIDE THE RECORD, OR CONVERT THE MOTION TO DISMISS INTO A MOTION FOR SUMMARY JUDGMENT, (2) CONVERTING DEFENDANT’S MOTION TO DISMISS INTO A MOTION FOR SUMMARY JUDGMENT, (3) DIRECTING LIMITED DISCOVERY AND SUPPLEMENTAL BRIEFING, (4) DENYING WITHOUT PREJUDICE THE PARTIES’ MOTIONS FOR SANCTIONS Plaintiff Cameron Thomson owns lakefront property on Long Lake in Hale, Michigan. In 2022, he sought to build a seawall and hired D&C Landscaping for the project. Because the property falls under Michigan’s environmental permitting laws, D&C applied for a permit with the relevant state agency, the Michigan Department of Environment, Great Lakes, and Energy (EGLE). In May 2023, Defendant Samantha Peterson, an EGLE employee, entered the property to conduct a compliance check—allegedly without a warrant based on consent given by D&C in the permit application process—and discovered nearly 80 feet of unpermitted seawall. Plaintiff then sued Defendant, alleging an unlawful Fourth Amendment search and a state-law trespass claim. Plaintiff insists that he never authorized D&C to consent to warrantless government entry on his land. Defendant moved to dismiss, contending that Eleventh Amendment sovereign immunity barred some of Plaintiff’s claims and that the rest of his claims lack viability. She attached an affidavit, application documents, and correspondence to her Motion to support her position. Plaintiff moved to strike or exclude those materials or alternatively convert Defendant’s Motion into a motion for summary judgment. Both Parties then filed dueling motions for sanctions, each accusing the other of advancing frivolous arguments.

For the reasons explained below, Plaintiff’s Motion to Strike or Exclude or Convert Defendant’s Motion to Dismiss into a motion for summary judgment, ECF No. 16, will be granted in part. Further, Defendant’s Motion to Dismiss, ECF No. 11, will be converted into a motion for summary judgment. As a result, the Parties will be directed to conduct limited discovery and file supplemental briefing upon completion of that discovery. And the Parties’ motions for sanctions, ECF Nos. 20; 21, will be denied without prejudice. I. A. Plaintiff Cameron Thomson owns lakefront property on Long Lake, an inland lake in Hale, Michigan. See ECF Nos. 8 at PageID.112–13; 8-1 at PageID.123. In 2022, Plaintiff wished to build a seawall on his property like many of his neighbors. See ECF No. 8 at PageID.113. So Plaintiff

hired an independent contractor, D&C Landscaping, to install the seawall. Id. But Plaintiff’s property falls within the regulatory framework established by Part 301 of Michigan’s Natural Resources and Environmental Protection Act (NREPA), MICH. COMP. LAWS § 324.30101 et seq. See id. at PageID.114. As a result, D&C needed to obtain a permit to build the seawall on Plaintiff’s behalf. Id.; see also MICH. COMP. LAWS § 324.30102 (requiring a permit to “[c]onstruct, enlarge, extend, remove, or place a structure on” an inland lake’s bottomland). Importantly, though, Plaintiff alleges that “[a]t no time was any agent or representative of D&C Landscaping given the authority or right to provide consent to the government [or] any of its agents, employees, or officials to” enter the property without a warrant. ECF No. 8 at PageID.114. In August 2022, D&C Landscaping’s owner, Thomas Kangas, digitally submitted to the Michigan Department of Environment, Great Lakes, and Energy (EGLE) a “Joint Permit Application” to obtain the necessary permit. See id. at PageID.114–15; see also ECF No. 8-4. Plaintiff alleges that “[o]n information and belief, D&C Landscaping” never conveyed Plaintiff’s

consent “for the government to warrantlessly enter, search, or inspect” his property. Id. at PageID.115. Plaintiff also alleges D&C would have acted beyond the bounds of its agency authority even if it had purported to convey such consent. Id. at PageID.114. At any rate, Defendant Samantha Peterson, the EGLE employee responsible for the permit application, required several rounds of revisions to the application. See ECF No. 8-4 at PageID.140–41. And according to a Michigan Department of Natural Resources (DNR) report attached to Plaintiff’s Amended Complaint as an exhibit, the permit was denied in February 2023 because Plaintiff’s property “lack[ed] erosion severity, and the site was also deemed low energy.” ECF No. 8-7 at PageID.150, 152. Yet Plaintiff apparently notified Defendant that he would install the seawall without a

permit. See id. at PageID.150–52. According to the DNR report, Defendant advised against the installation. Id. at PageID.151. On May 19, 2023, having not heard from Plaintiff or D&C, Defendant allegedly visited Plaintiff’s property and conducted a “compliance check.” Id.; see also ECF No. 8 at PageID.115–16. During this check, Defendant entered Plaintiff’s property without a warrant and discovered that “approximately 79 feet of new seawall had been installed without a permit.” ECF No. 8-7 at PageID.151; see also ECF No. 8 at PageID.116. Defendant also allegedly “collected information, took photographs, and generated other” evidence while on the property. ECF No. 8 at PageID.116. B. On July 9, 2024, Plaintiff sued Defendant in her official and individual capacities—seeking injunctive, declaratory, and monetary relief. ECF No. 1. In a later Amended Complaint, Plaintiff asserts two claims against Defendant. ECF No. 8 at PageID.116–18. First, Plaintiff brings a Fourth Amendment claim under 42 U.S.C. § 1983, alleging that Defendant’s May 19, 2023, compliance

check constituted an unlawful warrantless search of his property. Id. at PageID.116–17. Plaintiff specifies that he asserts this claim against Defendant in both her individual and personal capacities. Id. at PageID.117. Second, Plaintiff asserts a state-law trespass claim, alleging that Defendant trespassed on Plaintiff’s property when she conducted the compliance check. Id. Plaintiff does not specify in what capacity he sues Defendant for the trespass claim, but he does limit the relief he seeks to injunctive and declaratory relief for the claim. Id. On October 14, 2024, Defendant moved to dismiss the Amended Complaint. ECF No. 11. Defendant argues that Plaintiff’s official capacity claims are barred by Eleventh Amendment sovereign immunity, warranting their dismissal for lack of subject matter jurisdiction under Civil Rule 12(b)(1). Id. at PageID.181–92. Defendant further contends that Plaintiff has not alleged an

ongoing constitutional harm, so the exception to Eleventh Amendment immunity announced in Ex parte Young, 209 U.S. 123 (1908), does not apply. See generally id. As for Plaintiff’s individual capacity claims, Defendant argues that Plaintiff’s Complaint fails to state a viable claim because Defendant had consent to search Plaintiff’s property, warranting their dismissal under Civil Rule 12(b)(6). Id. at PageID.192–201. Importantly, Defendant attached several documents to her Motion that she uses to show that she had consent to inspect Plaintiff’s property. See ECF Nos. 11-1; 11-2.

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Thomson v. Peterson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomson-v-peterson-mied-2025.