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Spruytte v. Corrections Dept

Michigan Court of Appeals
Mar 21, 1978
82 Mich. App. 145 (Mich. Ct. App. 1978)

Summary

affirming grant of immunity to department of corrections and noting that "the prisoner transfer procedure . . . is an incident of the operation and maintenance of prisons and thus is within the scope of the performance of a uniquely governmental function"

Summary of this case from Asberry v. Rollins

Opinion

Docket No. 77-2347.

Decided March 21, 1978.

Appeal from the Court of Claims, James G. Fleming, J. Submitted February 16, 1978, at Lansing. (Docket No. 77-2347.) Decided March 21, 1978.

Complaint by Floyd Spruytte against the Department of Corrections for damages for the failure of defendant to return personal property turned over to agents of defendant. Judgment for defendant. Plaintiff appeals. Affirmed.

Shumar Murphy, for plaintiff.

Frank J. Kelley, Attorney General, Robert A. Derengoski, Solicitor General, and Michael J. Hodge, Assistant Attorney General, State Affairs Division, for defendant.

Before: DANHOF, C.J., and BRONSON and N.J. LAMBROS, JJ.

Circuit judge, sitting on the Court of Appeals by assignment.


Plaintiff, a prisoner, was transferred from Southern Michigan Prison to Marquette in August, 1973. In preparation for his transfer, plaintiff was required to turn over his personal property to the agents of the defendant. In return, he received a resident personal property receipt which itemized the property he had placed in the custody of the defendant. Plaintiff's property was never returned to him after his arrival at Marquette.

Plaintiff brought suit alleging that the resident personal property receipt constituted a bailment contract and claiming damages of $28,939.84 for breach. Defendant moved for accelerated and summary judgment on the ground that plaintiff's complaint was a disguised tort claim and that, as a tort claim, it was subject to the defense of governmental immunity. Plaintiff appeals from an order granting defendant's motion.

The trial court did not err in finding that the receipt did not constitute an express contract since it did not contain any contract terms. Therefore, any bailment relationship must be based on an implied contract. An implied contract, like other contracts, requires mutual assent and consideration. The parties did not appear to have any intention of entering into a contractual relationship since this procedure was required as an aspect of prison management and control. Furthermore, this purported contract lacks consideration since the parties were only performing a preexisting duty. As part of the transfer procedure, plaintiff was required to give up his property to the defendant, and the defendant was required to take it and hold it for him. Even if plaintiff was able to show a bailment contract, the Court could look beyond the contract label to determine whether the substance of the complaint sounded in tort. When significant public policy considerations are involved, the Court is not controlled by the labels chosen by the plaintiff, Greatrex v Evangelical Deaconess Hospital, 261 Mich. 327; 246 N.W. 137 (1933). In Greatrex, at 332, the Court quoted with approval the entire opinion of Rudy v Lakeside Hospital, 115 Ohio St. 539; 155 N.E. 126 (1926), where the Ohio court dismissed a similar action which attempted to circumvent a tort liability defense by pleading an implied contract of bailment.

Subject to certain statutory exceptions, all government agencies shall be immune from tort liability in all cases where the government agency is engaged in the exercise or discharge of a governmental function. MCLA 691.1407; MSA 3.996(107).

"Governmental function" is not defined by statute. It is, however, a term of art which has been used by the courts of this state to describe those activities of government which due to their public nature should not give rise to liability at common law. In the absence of prior judicial decision on whether a given activity is a governmental function, the courts will take a case-by-case approach. Thomas v Department of State Highways, 398 Mich. 1; 247 N.W.2d 530 (1976). The operation and maintenance of a jail is a governmental function. Green v Department of Corrections, 30 Mich. App. 648; 186 N.W.2d 792 (1971), aff'd, 386 Mich. 459; 192 N.W.2d 491 (1971), Wojtasinski v Saginaw, 74 Mich. App. 476; 254 N.W.2d 71 (1977). Furthermore, the prisoner transfer procedure, which required the plaintiff to be separated from his personal property, is an incident of the operation and maintenance of prisons and thus is within the scope of the performance of a uniquely governmental function.

Affirmed. No costs, a public question involved.


Summaries of

Spruytte v. Corrections Dept

Michigan Court of Appeals
Mar 21, 1978
82 Mich. App. 145 (Mich. Ct. App. 1978)

affirming grant of immunity to department of corrections and noting that "the prisoner transfer procedure . . . is an incident of the operation and maintenance of prisons and thus is within the scope of the performance of a uniquely governmental function"

Summary of this case from Asberry v. Rollins

In Spruytte v Dep't of Corrections, 82 Mich.App. 145; 266 N.W.2d 482 (1978), this Court considered a situation where the plaintiff, an incarcerated prisoner, brought suit against the Michigan Department of Corrections (MDOC) claiming damages for an alleged breach of a bailment contract, because the plaintiff's personal property was not returned to him after his transfer to another prison.

Summary of this case from Betty v. Dep't of Corr.

In Spruytte, the Court found that no implied bailment contract could be found to exist because (1) there was no mutual assent since the procedure for bailment of property upon incarceration was required as an aspect of prison management and control, and (2) there could be no finding of consideration since defendant was performing a preexisting duty.

Summary of this case from Pawlak v. Redox Corp.

In Spruytte, the Court found that no implied bailment contract could be found to exist because (1) there was no mutual assent since the procedure for bailment of property upon incarceration was required as an aspect of prison management and control, and (2) there could be no finding of consideration since defendant was performing a preexisting duty.

Summary of this case from Penner v. Seaway Hosp

In Spruytte, the Court found that no implied bailment contract could be found to exist because (1) there was no mutual assent since the procedure for bailment of property upon incarceration was required as an aspect of prison management and control, and (2) there could be no finding of consideration since defendant was performing a preexisting duty.

Summary of this case from Freiburger v. Mental Health

In Spruytte, the Court found that no implied bailment contract could be found to exist because (1) there was no mutual assent since the procedure for bailment of property upon incarceration was required as an aspect of prison management and control, and (2) there could be no finding of consideration since defendant was performing a preexisting duty.

Summary of this case from Guilbault v. Mental Health

In Spruytte, the Court found that no implied bailment contract could be found to exist because (1) there was no mutual assent since the procedure for bailment of property upon incarceration was required as an aspect of prison management and control, and (2) there could be no finding of consideration since defendant was performing a preexisting duty.

Summary of this case from Lowery v. Dep't of Corrections
Case details for

Spruytte v. Corrections Dept

Case Details

Full title:SPRUYTTE v DEPARTMENT OF CORRECTIONS

Court:Michigan Court of Appeals

Date published: Mar 21, 1978

Citations

82 Mich. App. 145 (Mich. Ct. App. 1978)
266 N.W.2d 482

Citing Cases

Betty v. Dep't of Corr.

In Spruytte v Dep't of Corrections, 82 Mich.App. 145; 266 N.W.2d 482 (1978), this Court considered a…

Nali v. City of Grosse Pointe Woods

However, even if plaintiff were able to show a bailment this Court does not look to the label chosen by…