Nonpayment of paid time off (PTO) benefits; MCL 408.473; District court jurisdiction; MCL 600.8301; Collateral estoppel; Application of preclusion doctrines to administrative decisions; William Beaumont Hosp v Wass; Privity; Adair v Michigan; At-will employment; Effect of just-cause employment status; Lytle v Malady (On Rehearing); Standing; Real party in interest; Ingham County Medical Care Facility (ICMCF); Wage & Hour Division (WHD)

The court held that the trial court 1) correctly dismissed all of plaintiff’s claims for PTO compensation on the ground they were precluded by collateral estoppel, 2) did not err by dismissing plaintiff’s claims based on a violation of a guarantee that he would be subject to termination only for just cause, and 3) did not err by dismissing his claim of fraudulent misrepresentation and concealment against defendant-Shanlian. The WHD found plaintiff, upon the involuntary termination of his employment with defendant-ICMCF, was not entitled to a payout of his accrued PTO. The decision was affirmed on administrative appeal and by the circuit court. Plaintiff then filed this action, alleging a variety of claims related to his PTO, the termination of his employment, and the alleged double repayment of unauthorized personal charges on the ICMCF credit card. The circuit court ultimately dismissed all the claims other than those seeking recovery of the overpayment. But it agreed with defendants that because that was the only facet of plaintiff’s case left standing, it no longer had jurisdiction. On appeal, the court rejected petitioner’s argument that the circuit court erred by finding the administrative action and appeal to the circuit court precluded relitigation of his claims for PTO compensation. “Because the circuit court in that earlier case held that the ICMCF, and the WHD in turn, correctly determined that plaintiff was not entitled to the PTO compensation . . . and because the circuit court additionally rejected [his] arguments as presented under the rubrics of conversion, due process, and equal protection, the court in this case correctly held that those claims based on disagreements with those approved administrative decisions may not here be revived, including by presenting those disagreements under additional common-law or constitutional rubrics.” As such, preclusion applied to defendant-county and the ICMCF. In addition, as privies of those institutions, preclusion also applied to the individual defendants. The court also rejected plaintiff’s claim that the circuit court erred by dismissing his claims predicated on violation of a guarantee of job security but for just cause, because the evidence established the existence of an oral and implied agreement for just-cause status. A statement made by a former administrator (O) “fell short of describing an unequivocal and enforceable institutional commitment to guaranteeing plaintiff employment but for just cause.” And O’s two affidavits did not create “an evidentiary conflict, but rather cannot reasonably be interpreted other than as the” circuit court did. Finally, the court found that because plaintiff’s claims against Shanlian were not distinct from those of the ICMCF, he lacked standing to raise them. Affirmed.