Macomb Intermediate School District v. State of Michigan

Summary

The Michigan Court of Appeals affirmed the Court of Claims' grant of summary disposition to the State of Michigan, the Michigan Department of Education, and the State Superintendent for Public Instruction. The court held that a statutory condition requiring schools receiving school safety and mental-health funding to waive applicable privileges during a mass-casualty investigation was not unconstitutionally vague or coercive and did not violate the Michigan Constitution's title-object clause or separation-of-powers doctrine. The excerpt addresses the meaning and scope of the privilege waiver and the statutory definition of a mass-casualty event.

Holdings

1. The privilege-waiver provision is not unconstitutionally vague. Read in context, 'any privilege' refers to privileges held by the school or district receiving funds and to information related to the particular mass-casualty event under investigation; the waiver lasts only during the comprehensive investigation.
2. The privilege-waiver condition is not unconstitutionally coercive because plaintiffs identified no constitutional right held by the schools or districts that they were required to waive, and individual employees' privileges are not waived by the statute.
3. MCL 388.1631aa(9) does not violate Const. 1963, art. 4, § 24 under the title-body, multiple-object, or change-of-purpose tests.
4. MCL 388.1631aa does not violate separation of powers.

Questions Presented

1. Whether MCL 388.1631aa(9)'s privilege-waiver condition is unconstitutionally vague.
2. Whether conditioning school-safety and mental-health funding on the privilege waiver violates the unconstitutional-conditions doctrine.
3. Whether the privilege-waiver provision violates the Michigan Constitution's title-object, multiple-object, or change-of-purpose requirements.
4. Whether the provision violates separation of powers by intruding on the judiciary's authority over legal privileges.

Disposition

affirmed