The Michigan Court of Appeals has ruled that Jeffrey M. Short's claim against the Michigan State Police (MSP) for disability discrimination is subject to a six-month notice requirement. This decision affects how employees can file claims under the Michigan Persons with Disabilities Civil Rights Act (PWDCRA). The court's ruling emphasizes the importance of adhering to legal timelines when pursuing discrimination claims against state agencies.
The case, Jeffrey M. Short v. Michigan State Police, was filed on August 3, 2026, under docket number 375823. The court's decision comes after Short alleged that he faced discrimination due to his posttraumatic stress disorder (PTSD) following a shooting incident while on duty. The ruling clarifies the legal procedures for filing claims against state entities, which can have significant implications for future cases involving employment discrimination.
Short began working for the Michigan State Police in 2000 and suffered a serious injury in the line of duty in 2013. After a promotion in 2022, he became embroiled in a scandal regarding officer promotions, which led to his suspension and subsequent demotion. Short claimed that his PTSD was exacerbated by these events and that MSP discriminated against him due to his disability. He filed a notice of intent to sue in October 2024, approximately nine months after the events that led to his claim.
The dispute centers around whether Short's claim is classified as a personal injury claim, which would require him to file a notice within six months, or if it falls under a different category with a longer notice period. The Michigan State Police argued that Short's case was indeed a personal injury claim, which led to the court's examination of the relevant statutes.
The Michigan Court of Appeals ruled that Short's claim does indeed qualify as a personal injury claim under the PWDCRA. Judge Sima G. Patel, writing for the court, stated, "A PWDCRA claim is a claim for 'personal injuries.' Accordingly, the COCA’s six-month notice provision... governs claims of employment discrimination on the basis of a disability in violation of the PWDCRA." This ruling reversed the trial court's earlier decision that had allowed Short's case to proceed.
The court's decision underscores the importance of the notice requirements established under the Court of Claims Act (COCA). The COCA mandates that claims against state entities must be filed within specific timeframes, which vary depending on the nature of the claim. In this case, the court determined that the six-month notice requirement applied, as Short's claim involved allegations of personal injury related to his disability.
This ruling has significant implications for employees seeking to file discrimination claims against state agencies in Michigan. It reinforces the necessity for claimants to be aware of and comply with the procedural requirements set forth in the COCA. Failure to adhere to these requirements can result in the dismissal of claims, as seen in Short's case.
The court's ruling may also impact other ongoing or future cases involving disability discrimination claims against state entities. Employees who believe they have been discriminated against based on their disabilities must ensure they file their notices of intent within the specified timeframes to preserve their rights to pursue legal action.
Looking ahead, it is unclear whether Short will appeal the court's decision. The ruling sets a precedent for how similar cases will be handled in the future, particularly regarding the interpretation of personal injury claims within the context of the PWDCRA. Legal experts will be watching closely to see if this decision influences other cases involving discrimination claims against state agencies in Michigan.