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CRAMER v. TRANSITIONAL HEALTH SERVICES

Docket No. 163559 Calendar No. 3.

1 N.W.3d 9 (2023)

512 Mich. 23

Agnes N. CRAMER, Plaintiff-Appellant, v. TRANSITIONAL HEALTH SERVICES OF WAYNE and American Zurich Insurance Company, Defendants-Appellees.

Supreme Court of Michigan.

Decided July 28, 2023.

Attorney(s) appearing for the Case

Mancini Schreuder Kline, PC, Warren (by Roger R. Kline) for plaintiff.

Giarmarco, Mullins & Horton, PC, Troy (by Adam Levitsky and Geoffrey S. Wagner) for defendants.

Lacey & Jones LLP, Troy (by Gerald M. Marcinkoski) for Michigan SelfInsurers' Association, amicus curiae.

Michael Reinholm, Assistant General Counsel, for AF Group, amicus curiae.

Adler Firm PLLC, Traverse City (by Barry Adler) and Cooper, Bender & Bender, PC (by Jacob C. Bender) for Michigan Association for Justice, amicus curiae.

BEFORE THE ENTIRE BENCH (except Bolden, J.).

OPINION

This case presents two questions arising under Michigan's Worker's Disability Compensation Act (MWDCA), MCL 418.101 et seq. First is whether the four-factor test laid out in Martin v Pontiac Sch Dist, 2001 ACO 118, lv. den. 466 Mich. 873, 645 N.W.2d 665 (2002), conflicts...

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