Phillips v. Mirac, Inc., 470 Mich. 415

Summary

The Supreme Court of Michigan held that MCL 257.401(3), which caps a short-term motor vehicle lessor's vicarious liability at $20,000 per injured person and $40,000 per accident, does not violate the Michigan Constitution. The court concluded that the cap does not infringe the right to a jury trial because juries determine facts and damages, while courts determine the legal consequences of those findings. The court also upheld the statute against equal protection and substantive due process challenges under rational-basis review.

Holdings

1. MCL 257.401(3)'s limitation on the amount recoverable from a short-term vehicle lessor does not violate the Michigan constitutional right to trial by jury because the jury determines the facts and damages, while the court determines the legal consequences and limits of liability.
2. MCL 257.401(3) does not violate the Michigan Constitution's Equal Protection Clause because the classification is rationally related to legitimate governmental interests.
3. MCL 257.401(3) does not violate the Michigan Constitution's substantive due process guarantee.

Questions Presented

1. Whether MCL 257.401(3)'s cap on a short-term motor-vehicle lessor's vicarious liability violates the Michigan Constitution's right to trial by jury.
2. Whether the damages cap violates the Michigan Constitution's Equal Protection Clause.
3. Whether the damages cap violates the Michigan Constitution's Due Process Clause.

Disposition

affirmed