Michigan

Devlin v. Scardelletti in Michigan Law

How Devlin v. Scardelletti applies in Michigan: state-specific rules, key cases, and bar exam notes for Civil Procedure.

State Approach

Michigan follows a similar approach to the issue of intervenor rights as discussed in Devlin v. Scardelletti, emphasizing the necessity of timely intervention in ongoing litigation. The courts recognize the importance of protecting intervenors' interests while balancing the principal parties’ rights.

State Rule
In Michigan, a non-party may intervene in a legal matter if they have a substantial interest in the subject matter and timely file a motion for intervention, as governed by MCR 2.209.
Significant State Cases

In re Dorsey Trust

The Michigan Court of Appeals upheld the right of an interested party to intervene in probate matters when a substantial interest is at stake.

Farm Bureau Mutual Insurance Co. v. Kauffman

The court ruled that an intervention is warranted when the intervenor's ability to protect their interests would otherwise be impeded.

Locke v. Carriage House Apartments

The court enforced a liberal interpretation of MCR 2.209, allowing intervention in cases involving real estate disputes where third parties had significant stakes.

Comparison to Federal Law

Michigan's approach parallels the federal standard set by Rule 24 of the Federal Rules of Civil Procedure, which allows intervention when a party claims an interest and is situated in a manner that may be impaired. However, Michigan courts emphasize a more specific analysis of timeliness and the interests affected compared to the federal framework.

Bar Exam Note

Questions regarding intervention and the rights of parties and non-parties in civil procedure often appear in the Michigan bar exam, underlining the importance of understanding MCR 2.209.

Practice Pointers
  • Always establish standing and a substantial interest before moving to intervene in any case.
  • Pay careful attention to the timeline for filing a motion to intervene; delays can lead to denial regardless of the merits.
  • Review similar case law for precedent on the type of interest that justifies intervention in complex litigation.

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