Wayne County Sheriff v. Wayne County Board of Commissioners

494 N.W.2d 14, 196 Mich. App. 498
CourtMichigan Court of Appeals
DecidedNovember 2, 1992
DocketDocket 132846
StatusPublished
Cited by5 cases

This text of 494 N.W.2d 14 (Wayne County Sheriff v. Wayne County Board of Commissioners) 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
Wayne County Sheriff v. Wayne County Board of Commissioners, 494 N.W.2d 14, 196 Mich. App. 498 (Mich. Ct. App. 1992).

Opinions

Reilly, J.

This case involves a dispute regarding Wayne County Sheriff Robert Ficano’s request to the Wayne County Board of Commissioners for payment of attorney fees incurred in defending against a petition to appoint a receiver for the Wayne County Jail. The petition was filed by the Wayne County Executive, Edward McNamara, in a Wayne Circuit Court action brought by prisoners in 1971 against the Wayne County Executive, the chairman of the Wayne County Board of Commissioners, the sheriff, and the jail administrator seeking to improve jail conditions.

McNamara petitioned the court to relieve Sheriff Ficano of his jail responsibilities and have himself appointed as receiver of the jail on August 15, 1988. The hearing on the motion was scheduled for August 29, 1988. In separate letters dated August 16 and 17, 1988, both the Wayne County Prosecuting Attorney and the Wayne County Corporation Counsel advised the sheriff that their offices would be unable to represent him to defend against the receivership petition. On August 15, [501]*5011988, Ficano sought authorization from the board of commissioners to retain outside legal counsel to represent his interests. On the same day, Ficano retained outside legal counsel. McNamara objected to the request for outside counsel, arguing to the board that Ficano’s in-house counsel, Adam Angelas, should represent Ficano in the receivership proceeding. On August 25, 1988, the board, by resolution, tentatively approved Ficano’s request for use of outside legal counsel in the receivership proceeding.1 It is undisputed that the board rejected McNamara’s argument when it authorized outside counsel, but the record does not indicate its reasons for doing so.

On September 1, 1988, the inmates filed their own petition requesting that an independent receiver be appointed. On September 13, 1988, McNamara formally withdrew his petition to be appointed receiver. However, after his withdrawal, McNamara filed court documents and made appearances through counsel, arguing that should the court decide to appoint a receiver, he was the logical choice.

On October 6, 1988, the commissioners passed a second resolution, revoking their approval of pay[502]*502ment of fees to Ficano’s outside legal counsel, conditioned upon their chairman’s receipt of a letter from the corporation counsel that his office could represent - Ficano. Again, nothing in the resolution or in the record refers to the availability of Angelas to represent the sheriff in the receivership proceedings. On October 7, 1988, the corporation counsel sent the chairman, Arthur Carter, a letter stating that because McNamara had withdrawn his petition to be appointed receiver, he could lawfully provide legal representation to the sheriff. Nevertheless, Ficano continued to retain outside legal counsel to represent him in the receivership proceeding.

In late 1988, Ficano submitted an invoice to the board of commissioners for attorney fees for the period August 15, 1988, to September 30, 1988. The board referred the invoice to its legislative tribunal, which adopted a resolution authorizing payment in full. However, the board refused to pay the invoice except for $3,457.25 in counsel’s out-of-pocket expenses.

On February 16, 1989, the trial court granted the motion for receivership, naming McNamara as the receiver. Ficano appealed and filed a motion for stay, which was denied by this Court, McDonald, P.J., and Holbrook, Jr., and Murphy, JJ., on March 16, 1989 (Docket No. 115672). Our Supreme Court reversed, stayed the receivership order on March 24, 1989, and ordered this Court’s expeditious hearing and decision of the case. Wayne Co Jail Inmates v Wayne Co Chief Executive Officer #2, 432 Mich 882 (1989). This Court, Cynar, P.J., and Wahls and Marilyn Kelly, JJ., then held, inter alia, that the receivership order was proper. Wayne Co Jail Inmates v Wayne Co Chief Execu[503]*503tive Officer, 178 Mich App 634; 444 NW2d 549 (1989). Our Supreme Court again stayed the receivership order in an order dated August 15, 1989, while an application for leave to appeal remained under' consideration. On November 30, 1989, the parties entered into a consent judgment whereby McNamara and Ficano agreed to jointly appoint Peter Wilson as Director of Jail Operations, who would report to McNamara on all budget matters and to Ficano on all security and operational matters. On February 21, 1990, the Supreme Court entered an order dismissing the appeal pursuant to the consent judgment.

On June 21, 1989, before entry of the consent judgment, Ficano commenced this action against the Wayne County Board of Commissioners, seeking to recover attorney fees in excess of $400,000, allegedly incurred by him in defending against the petition for receivership. On February 28, 1990, intervening defendant McNamara filed a motion for summary disposition of the issue of the board’s liability for attorney fees. In March 1990, Ficano and the board filed similar motions. On May 8, 1990, the trial court issued a written opinion and order granting defendants’ motions for summary disposition regarding the board’s liability for Ficano’s attorney fees incurred before August 25, 1988, and after October 7, 1988. The court also granted Ficano’s motion for summary disposition regarding the .board’s obligation to pay those fees incurred between August 25, 1988, and October 7, 1988. All the motions were granted pursuant to MCR 2.116(C)(10). Basically, the court determined that the board was liable only for those fees incurred by Ficano for the period August 25, 1988, to October 7, 1988, while the resolution authorizing outside counsel was in effect. On August 24, 1990, the trial court entered a final judgment, ordering the board to pay plaintiff $56,560.75 in attorney fees [504]*504for that period. Plaintiff Ficano appeals as of right from the final order granting defendants’ motions. Defendants have not filed a cross appeal.2

i

Plaintiff first argues that the trial court erred in recognizing the validity of the commissioners’ October 6, 1988, resolution wherein the commissioners revoked their authorization for plaintiff to retain outside counsel.

Plaintiff argues that the board could not legally revoke its authorization for plaintiff’s outside counsel and that the October 6, 1988, resolution is void because: (1) the board had a statutory duty to provide him with counsel, (2) the conflict between him, the board, and McNamara was not extinguished with McNamara’s withdrawal, and (3) the corporation counsel could not represent him while the conflict existed. Plaintiff also contends that the crisis situation demanded immediate retention of outside counsel and Angelas could not handle the increase in work without the continued assistance from the corporation counsel’s legal staff.3 The board argues that no conflict of interest existed after McNamara’s withdrawal of his petition that would preclude representation of Ficano by the corporation counsel. McNamara does not contend that no conflict existed, but, rather, that it is irrelevant because the county’s statutory obligation to provide legal counsel to the sheriff was satisfied by the continued employment of Angelas, [505]*505who was paid by the county to represent the sheriffs interests exclusively.

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Related

Mercer v. City of Lansing
733 N.W.2d 89 (Michigan Court of Appeals, 2007)
Lee v. MacOmb County Board of Commissioners
597 N.W.2d 545 (Michigan Court of Appeals, 1999)
Wayne County Sheriff v. Wayne County Board of Commissioners
494 N.W.2d 14 (Michigan Court of Appeals, 1992)

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Bluebook (online)
494 N.W.2d 14, 196 Mich. App. 498, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wayne-county-sheriff-v-wayne-county-board-of-commissioners-michctapp-1992.