Quasi-judicial immunity; Denhof v Challa; Intentional infliction of emotional distress (IIED); Gross negligence; Claims based on alleged falsification of business records produced pursuant to court order; Maiden v Rozwood; Estate of Voutsaras by Gaydos v Bender; Silas v Reilly (Unpub); Statute of limitations; Intentional interference with contractual relations (IICR)

The court held that plaintiff-White’s claims were in part barred by quasi-judicial immunity and the statute of limitations. According to the complaint, defendant-Munyan is the owner of defendant-Floor Savers. White was employed as Floor Savers’ chief financial officer from 2014 until his resignation in 2018. The complaint alleged “Munyan submitted an allegedly fraudulent insurance claim with” an insurance company, “stating that White and another former Floor Savers employee embezzled approximately $90,000 from the company during their employment.” A police report was also filed, and White was charged with embezzlement based on the report. The criminal case was eventually dismissed. Plaintiff then filed this action alleging claims for IIED, IICR, gross negligence, and stalking. The trial court denied defendants’ summary disposition motion. On appeal, the court concluded “White’s claims are barred by quasi-judicial immunity to the extent they are based on Munyan’s filing of the police report, testimony at the preliminary examination, or production of documents or records pursuant to court order.” As a result, Munyan was entitled to summary disposition on the “gross negligence claim and, to some extent, on White’s IIED claim.” While Munyan was “not entitled to immunity for White’s IICR and stalking claims,” these claims and his IIED claim were time-barred to the extent they were based on harm incurred before 3/17/19, three years before White filed his initial complaint.