The Michigan Court of Appeals has ruled that the Wayne County Community College District (WCCCD) cannot dismiss claims of discrimination and harassment brought by former employees Bonita Carey-Powers and Alexis Holmes. The court's decision, issued on August 14, 2026, allows the plaintiffs to pursue their claims without having to meet certain notice requirements. This ruling is significant for individuals alleging workplace discrimination and harassment, as it clarifies the legal obligations of community colleges in Michigan.
The case, Bonita Carey-Powers v. Wayne County Community College District, stems from allegations that the plaintiffs faced disparate treatment based on their sex, endured a hostile work environment, and experienced retaliation for reporting sexual harassment by Darrick Muhammad, the security director at WCCCD. The plaintiffs worked for the college's police force and claimed that their complaints were not taken seriously, leading to a toxic work environment.
The dispute reached the Michigan Court of Appeals after WCCCD filed a motion for summary disposition, arguing that the plaintiffs had not complied with the notice requirements set forth in the Court of Claims Act. Specifically, WCCCD contended that the plaintiffs failed to file a written claim or notice of intention to file a claim within one year of the alleged incidents, as required by Michigan law. The trial court denied WCCCD's motion, prompting the college to appeal the decision.
Background
Bonita Carey-Powers and Alexis Holmes, both employees of WCCCD's police force, claimed that they were subjected to discrimination and harassment by their superior, Darrick Muhammad. The allegations included a hostile work environment and retaliation for reporting Muhammad's inappropriate behavior. The plaintiffs argued that their treatment was based on their sex, which violates the Elliott-Larsen Civil Rights Act.
WCCCD responded to the allegations by filing a motion for summary disposition, asserting that the plaintiffs had not provided sufficient evidence to support their claims and that they failed to comply with the notice requirements of the Court of Claims Act. The trial court's decision to deny the motion allowed the case to move forward, leading to the appeal by WCCCD.
The Ruling
The Michigan Court of Appeals ruled in favor of the plaintiffs, affirming the trial court's decision to deny WCCCD's motion for summary disposition. The court emphasized that the plaintiffs were not required to comply with the notice provisions of the Court of Claims Act, as WCCCD does not qualify as a state entity under the law.
The court stated, "WCCCD does not fall within the definition of 'the state or any of its departments or officers'; therefore, plaintiffs’ claims were not subject to the notice requirement of MCL 600.6431."
The ruling clarified that community colleges, such as WCCCD, are considered local entities rather than state entities. This distinction is crucial because it means that the notice requirements that apply to claims against the state do not apply to claims against community colleges. The court referenced a previous case, Doan v. Kellogg Community College, which established that community colleges are governed by local votes and are not subject to the same jurisdiction as state entities.
Impact
This ruling has significant implications for employees of community colleges and other local educational institutions in Michigan. It reinforces the idea that employees can pursue claims of discrimination and harassment without being hindered by strict notice requirements that apply to state entities. The court's decision also highlights the importance of protecting employees' rights in the workplace, particularly in cases involving allegations of sexual harassment and discrimination.
The ruling may encourage more individuals to come forward with claims against their employers, knowing that they may not face the same barriers that exist when dealing with state entities. Additionally, this decision could set a precedent for future cases involving community colleges and their responsibilities under civil rights laws.
What's Next
WCCCD may seek to appeal the ruling to the Michigan Supreme Court, as the case raises important questions about the application of the Court of Claims Act and the definition of governmental entities. However, as of now, the case will proceed in the lower courts, allowing the plaintiffs to present their claims against WCCCD and Darrick Muhammad.