Legal Memorandum: Judgment as a Matter of Law in MI

Issue: Under the laws of Michigan, when is a defendant entitled to judgment as a matter of law?

A defendant is entitled to judgment in an action as a matter of law where there is no genuine issue of material fact.  MCR 2-116(C)(10).  Michigan Court Rules dictate that the Court "render judgment without delay," where "the affidavits or other proofs show that there is no genuine issue of material fact."  MCR 2-116(I)(1).  Under the Rule, the Court "must review the documentary evidence and determine whether a genuine issue of material fact exists . . . draw[ing] all reasonable inferences in the nonmovant’s favor, giving that party the benefit of any reasonable doubt."  Paul v. Lee, 455 Mich 204; 568 NW2d 510, 513, reh’g denied, 568 NW2d 670 (Aug. 27, 1997); accord Singerman v. Municipal Serv Bur, Inc, 455 Mich 135; 565 NW2d 383, 385 (1997); Bertrand v. Alan Ford, Inc, 449 Mich 606; 537 NW2d 185, 190 (1995).  If the nonmovant fails to come forward with evidence to establish the existence of a disputed material fact, the motion for summary disposition is properly granted.  Paul, 568 NW2d at 513.  "When the cause remains one of pure speculation or conjecture, or the probabilities are evenly balanced," summary disposition is appropriate.  Auto Club Ins. Ass’n v General Motors Corp, 217 Mich App 594; 552 NW2d 523, 528 (1996) (holding that the plaintiff failed to establish that the defendant caused the accident).  The court "does not have to remain idle in the presence of undisputed, uncontroverted facts. . . . [When] the only question remaining is what legal conclusion can be draw from the facts [the] […]