Supreme overturns Court of Appeals; hold no "equitable tolling" of statute of limitations where parties attempted dispute resolution
The Michigan Supreme Court recently overturned a Court of Appeals decision in a case where the parties to a religious "congregational" dispute attempted to involve the courts in its resolution. The parties had engaged in dispute resolution through ecclesiastical procedures. When they were ineffective--or at least unsatisfactory to one of the parties, a suit was filed to determine ownership of property.
The Court of Appeals, relying on a prior Michigan holding, held that the statute of limitations was equitably tolled (extended) while parties engaged in mandatory dispute resolution. The Supreme Court reversed, holding that the mandatory exhaustion of religious dispute resolution remedies did not equitably extend the statute of limitations.