Plaintiff loses breach of fiduciary duty claim (no claim for lack of good faith and fair dealing); owes sanctions and attorneys' fees; loses disqualification argument
In Blackward Props. LLC v. Sower, the plaintiff lost a claim arising out of business dealings and a proposed property devleopment with the Defendants. It argued that it was owed a fiduciary duty by its broker, one of the defendants. The Court held that a fiduciary duty is not normally recognized in an adversary or buyer-seller relationship and that Michigan "does not recognize an independent claim for breach of the covenant of good faith and fair dealing." The Court also held that it was not error for the trial judge to issue binding rulings in the month before she disqualified herself from hearing the remainder of the case.