Court overturns summary disposition for plaintiff and remands for damage calculation
First State Title sued LP Recordings after the latter failed to file various documents in County Registers of Deeds. The Plaintiff was granted summary disposition on contract claims and also held that a "conversion" [essentially theft] had occurred by reason of the Defendant's failure to record the documents after receiving payment. The Court of Appeals ruled that there was no way to trace specific funds to specific transactions, and therefore no basis to uphold the conversion element of the plaintiff's claim.