McCAHAN v. BRENNAN

YOUNG, C.J.

In Rowland v Washtenaw County Road Commission,1 this Court held that, it being the sole province of the Legislature to determine whether and on what terms the state may be sued, the judiciary has no authority to restrict or amend those terms. We take this opportunity to reaffirm and apply this fundamental principle articulated in Rowland to the interpretation of MCL 600.6431, the notice provision of the Court of Claims Act at issue in this case.

The Court of Appeals correctly determined that when the Legislature conditions the ability to pursue a claim against the state on a plaintiffs having filed specific statutory notice, the courts may not engraft an “actual prejudice” component onto the statute as a precondi*733tion to enforcing the legislative prohibition. We reiterate the core holding of Rowland that such statutory notice requirements must be interpreted and enforced as plainly written and that no judicially created saving construction is permitted to avoid a clear statutory mandate. We further clarify that Rowland applies to all such statutory notice or filing provisions, including the one at issue in this case.

I. facts and procedural history

Plaintiff, Christina McCahan, was injured in an automobile accident on December 12, 2007. The collision involved a student who was driving a car owned by the University of Michigan. Plaintiff sought to recover damages from the university for her injuries. MCL 600.6431 requires any person who wishes to bring an action against state entities for personal injury or property damage to file with the Clerk of the Court of Claims either a specific statutory notice of intent to pursue a claim or the claim itself within six months of the incident giving rise to the cause of action. MCL 600.6431 provides:

(1) No claim may be maintained against the state unless the claimant, within 1 year after such claim has accrued, files in the office of the clerk of the court of claims either a written claim or a written notice of intention to file a claim against the state or any of its departments, commissions, boards, institutions, arms or agencies, stating the time when and the place where such claim arose and in detail the nature of the same and of the items of damage alleged or claimed to have been sustained, which claim or notice shall be signed and verified by the claimant before an officer authorized to administer oaths.
(3) In all actions for property damage or personal injuries, claimant shall file with the clerk of the court of *734claims a notice of intention to file a claim or the claim itself within 6 months following the happening of the event giving rise to the cause of action.[2]

Plaintiff did not file a verified notice of intent to file a claim with the Clerk of the Court of Claims within six months after the accident. However, plaintiff and her counsel undertook numerous efforts to inform the university’s legal office of her intent to seek recovery against the university. These actions included plaintiffs counsel’s sending a letter to the university’s legal office, plaintiff and her counsel meeting with and providing all then available documentation relating to the accident to the university’s senior claims representative by the six-month deadline of June 12, 2008, and plaintiffs continuing to provide further information to the representative thereafter. On October 31,2008, more than 10 months after the accident, plaintiff filed with the Clerk of the Court of Claims a notice of intent to bring suit against the university. Plaintiff filed her action against the university in the Court of Claims on December 5, 2008.

The university subsequently moved for summary disposition, contending that plaintiffs failure to file notice of intent to file a claim or the claim itself within the six-month deadline required dismissal of her claim. The Court of Claims agreed, ruling that the six-month deadline of MCL 600.6431(3) is a modification of the requirements provided in MCL 600.6431(1) and thus the prohibition against maintaining a claim from subsection (1) applied because plaintiff had not filed her claim or notice of her intent to file a claim within six months. The court further ruled that plaintiffs arguments that she had substantially complied with the statute and that defendant suffered no prejudice as a result of any defects in notice failed in light of the specific language of the statute *735requiring the filing within six months after the accident in order to maintain the claim.

On appeal, the Court of Appeals affirmed in a split decision.3 The Court of Appeals majority held that the filing of notice with the Court of Claims is a mandatory statutory requirement. Then, relying on the principles articulated in Rowland, the majority rejected plaintiffs argument that substantial compliance or the absence of prejudice to defendant could save plaintiffs claim.4 The Court of Appeals dissent would have held that the university’s actual knowledge of plaintiffs intent to file a claim sufficed to satisfy the statutory notice requirement of MCL 600.6431.5

We ordered argument on plaintiffs application for leave to appeal6 and now affirm.

II. STANDARD OF REVIEW

This Court reviews de novo a lower court’s decision to grant summary disposition to a party.7 Further, *736whether MCL 600.6431 requires dismissal of a plaintiffs claim for failure to provide the designated notice raises questions of statutory interpretation, which we likewise review de novo.8 Our primary objective when interpreting a statute is to discern the Legislature’s intent. “This task begins by examining the language of the statute itself. The words of a statute provide ‘the most reliable evidence of its intent....’ ”9 When the Legislature has clearly expressed its intent in the language of the statute, no further construction is required or permitted.10

III. ANALYSIS

Generally, governmental agencies in Michigan are statutorily immune from tort liability.11 However, because the government may voluntarily subject itself to liability, it may also place conditions or limitations on the liability imposed.12 One such condition on the right to sue the state is the notice provision of the Court of Claims Act, MCL 600.6431, which provides in full:

(1) No claim may be maintained against the state unless the claimant, within 1 year after such claim has accrued, files in the office of the clerk of the court of claims either a written claim or a written notice of intention to file a claim *737against the state or any of its departments, commissions, boards, institutions, arms or agencies, stating the time when and the place where such claim arose and in detail the nature of the same and of the items of damage alleged or claimed to have been sustained, which claim or notice shall be signed and verified by the claimant before an officer authorized to administer oaths.
(2) Such claim or notice shall designate any department, commission, board, institution, arm or agency of the state involved in connection with such claim, and a copy of such claim or notice shall be furnished to the clerk at the time of the filing of the original for transmittal to the attorney general and to each of the departments, commissions, boards, institutions, arms or agencies designated.
(3) In all actions for property damage or personal injuries, claimant shall file with the clerk of the court of claims a notice of intention to file a claim or the claim itself within 6 months following the happening of the event giving rise to the cause of action.

Thus, MCL 600.6431 sets forth several requirements that must be met in order to bring suit against a governmental entity in derogation of governmental immunity. Pursuant to subsection (1), “[n]o claim may be maintained against the state” unless the claimant files “in the office of the clerk of the court of claims” either a written claim or a written notice of intent to file a claim within one year. The claim or notice must contain certain information, including the time and place that the claim arose, the nature of the claim, and the damages alleged and must be “signed and verified by the claimant before an officer authorized to administer oaths.” Pursuant to subsection (2), “[s]uch claim or notice shall designate any. .. agency of the state involved in connection with such claim . . . .” And “a copy of such claim” shall be provided upon filing for the clerk to transmit to the Attorney General and the appropriate governmental agency. Finally, pursuant to *738subsection (3), if the claim against the state is one for “property damage or personal injuries,” the claimant must file with “the clerk of the court of claims” a notice or claim “within 6 months” of the incident — not one year, as is otherwise applicable to claims pursuant to subsection (1).

Plaintiffs appeal before this Court essentially raises two questions. First, what is the relationship between subsection (3), to which plaintiffs personal injury claim applies, and subsection (1)? In particular, does the bar-to-claims language of subsection (1) (“[n]o claim may be maintained against the state unless”) apply to personal injury claims covered by subsection (3)? Second, what effect must be given to a failure to file either a claim or notice of intent to file a claim pursuant to subsection (3), particularly when a state entity otherwise received actual notice of plaintiffs injury?

We believe that a contextual understanding of MCL 600.6431 readily resolves the first question and that this Court’s decision in Rowland has already decided the second. We hold that subsection (3) must be read in light of subsection (1), including that provision’s prohibition on maintaining a suit as a consequence of a failure to file compliant notice within six months. In accordance with Rowland, we reaffirm that when the Legislature conditions the ability to pursue a claim against the state on a plaintiffs having provided specific statutory notice, the courts may not engraft an “actual prejudice” component onto the statute before enforcing the legislative prohibition.

A. MCL 600.6431 AS A CONTEXTUAL WHOLE

As a threshold matter, plaintiff argues that her claim, being a claim for personal injury, is not subject to the dictates or bar-to-claims language of MCL 600.6431(1). *739Instead, plaintiff argues that only subsection (3) governs her claim and acts as an independent provision that excludes application of subsection (1). Accordingly, plaintiff argues that the failure of the Legislature to state that “[n]o claim may be maintained against the state” in subsection (3) as it has done in subsection (1) indicates that any failure to meet the notice requirements of subsection (3) does not subject a party to the prohibition on maintaining a claim against the state contained in subsection (1). As the lower courts did, we reject plaintiffs argument that subsection (3) must be read in isolation, segregated from the language, requirements, and context provided in subsection (1).

When undertaking statutory interpretation, the provisions of a statute should be read reasonably and in context.13 Doing so here leads to the conclusion that MCL 600.6431 is a cohesive statutory provision in which all three subsections are connected and must be read together. Subsection (1) sets forth the general notice required for a party to bring a lawsuit against the state, while subsection (3) sets forth a special timing requirement applicable to a particular subset of those cases — those involving property damage or personal injury. Subsection (3) merely reduces the otherwise applicable one-year deadline to six months. In this regard, subsection (3) is best understood as a subset of the general rules articulated in subsection (1), and those general rules and requirements articulated in subsection (1) — including the bar-to-claims language— continue to apply to all claims brought against the state unless modified by the later-stated specific rules.

Our decision in Robinson v City of Lansing14 is instructive in this regard. In Robinson, we interpreted *740the so-called “two-inch rule” of the highway exception to governmental liability, MCL 691.1402a, which sets forth a general rule in subsection (1) applicable to “county highways,” followed by additional rules and exceptions in further subsections that speak only generically of “the highway.” The issue before the Court was whether the rules in the additional subsections were limited like subsection (1) to “county highways” or whether they also applied to “state highways” like the one on which the plaintiff was injured. We unanimously held that there were sufficient textual indicia to determine that the references to highways in each of the subsections referred to county highways, even though subsection (1) was the only subsection explicitly referring to “county highways.” In support of this conclusion, we held that there were no indications in the latter subsections that the scope of those subsections was different from subsection (1).15 Further, we stated that “statutory provisions are not to be read in isolation; rather, context matters, and thus statutory provisions are to be read as a whole.”16 Thus, the fact that the Legislature did not expressly use the word “county” in the latter provisions did not mean that the prior use did not carry through to latter subsections. Finally, we noted that “the Legislature is not required to be overly repetitive in its choice of language.... Instead, we believe that a reasonable person reading this statute would understand that all three subsections of this provision apply only to county highways” even though the Legislature did not “repetitively restate ‘county’ throughout the entire statutory provision.”17

*741Like Robinson, this case requires that we determine the extent to which language from one subsection of a statute applies to another subsection of the same statute. And as in Robinson, we believe that a reasonable person reading the statute would understand that subsections (1) and (3) are related and interdependent. Most important, the context of the entire statutory provision indicates that the six-month filing requirement for personal injury or property damage cases is a modification of the generally applicable one-year filing requirement. There is no indication from the language used that the provisions of subsection (1) do not apply to subsection (3), and the Legislature need not be overly repetitive in reasserting the requirements for notice in each subsection when the only substantive change effectuated in subsection (3) is a reduction in the timing requirement for specifically designated cases.

Further support for this conclusion is derived from the text of the statute itself. Subsection (3) begins with the prefatory phrase “[i]n all actions for property damage or personal injuries.” Yet, the Court of Claims only has jurisdiction over claims brought against the state.18 Thus, with this language the Legislature was obviously not referring to “all actions for property damage or personal injuries,” but only to those actions “against the state,” as limited in subsection (1). If subsection (3) were to be read in isolation, without reference to what the Legislature had already set forth in subsection (1), it would be impossible to reasonably interpret subsection (3)’s prefatory clause.

Moreover, the various subsections of MCL 600.6431 refer to each other. For example, subsection (3) employs the phrase “notice of intention to file a claim,” which is *742the same phrase that is used and defined in detail in subsection (1). Similarly, subsection (2) directly refers to subsection (1) by noting that “[s]uch claim or notice” as described in subsection (1) must designate the responsible governmental agency; this language clearly indicates that subsection (2) is an elaboration of the requirements stated in subsection (1). Reading this statute as a whole, it is reasonably clear that these subsections are not independent entities that happen to be grouped together in the same statutory provision. Instead, they are related and interdependent, and thus cannot be read in isolation.

Thus, in accordance with prior interpretations of MCL 600.6431, we conclude that the statutory provision must be understood as a cohesive whole.19 Subsection (1) sets forth the general rule, for which subsection (2) sets forth additional requirements and which subsection (3) modifies for particular classes of cases that would otherwise fall under the provisions of subsection (1). Accordingly, subsection (3) incorporates the consequence for noncompliance with its provisions expressly stated in subsection (1) and does not otherwise displace the specific requirements of subsection (1) other than the timing requirement for personal injury or property damage cases. Therefore, the failure to file a compliant claim or notice of intent to file a claim against the state within the relevant time periods designated in either subsection (1) or (3) will trigger the statute’s prohibition that “[n]o claim may be maintained against the state . . ..”

*743B. APPLICATION OF ROWLAND

Having concluded that the bar-to-claims language of MCL 600.6431(1) applies to this case because plaintiff failed to file a claim or notice of intent to file a claim with the Clerk of the Court of Claims within six months, we must also address whether dismissal is required. Plaintiff argues that the university was not prejudiced by her failure to file notice of intent to file her claim in the Court of Claims within six months because she otherwise timely provided the university’s legal office with notice of the accident, information sufficient to investigate the accident, and notice of her intent to bring suit if necessary to resolve her claim. We disagree. The lower courts correctly held that plaintiffs failure to file the required notice in the Court of Claims bars her action regardless of whether the university was otherwise put on notice of plaintiffs apparent intent to pursue a claim. The reasoning of Rowland is directly on point and thus controls this matter.

In Rowland, we interpreted the highway exception to governmental immunity, and in particular, its statutory requirement that “[a]s a condition to any recovery for injuries,” an injured person must provide notice within 120 days from the time the injury occurred.20 The plaintiff in Rowland served notice on the defendant after 140 days, thus failing to meet the 120-day deadline. Examining whether this failure precluded the plaintiff from maintaining her claim, this Court rejected earlier caselaw that had assumed that notice provisions are constitutional only if they contain a prejudice requirement.21 Instead, Rowland held that *744when the plain language of a statute requires particular notice as a condition for recovery, “no ‘saving construction’ [is] necessary or allowed. Thus, the engrafting of [a] prejudice requirement onto the statute [is] entirely indefensible.”22

Rowland noted that notice provisions are enacted by the Legislature in order to provide the state with the opportunity to investigate and evaluate claims, to reduce the uncertainty of the extent of future demands, or even to force the claimant to an early choice regarding how to proceed.23 Provisions requiring notice to a particular entity, like the Court of Claims in this case, further ensure that notice will be provided to the proper governmental entity, thereby protecting plaintiffs and defendants alike from having the wrong component of government notified.24

As in Rowland, the statutory language at issue here is clear. MCL 600.6431(1) details the notice requirements that must be met in order to pursue a claim *745against the state, including a general deadline of one year after accrual of the claim. MCL 600.6431(3) then modifies only the deadline requirement for a specific class of claims — those involving personal injury or property damage — replacing the one-year deadline with a six-month deadline. Thus, subsections (1) and (3) together provide that in all actions for personal injuries, “[n]o claim may be maintained against the state” unless the claimant files with the Clerk of the Court of Claims the required notice of intent to file a claim or the claim itself within six months. Indeed, this notice provision is substantively identical to the provision in Rowland.25 Because plaintiff here failed to file any notice of an intent to pursue a claim against the university with the Court of Claims within six months, plaintiffs claim is barred by the plain language of the statute.

There has been some dispute in the Court of Appeals as to whether the holding of Rowland is limited to cases involving the highway exception to governmental immunity, MCL 691.1404(1), which Rowland interpreted.26 This dispute unfortunately might have been created by concurrences filed in several orders of this Court that called into question whether Rowland was for some reason limited to the specific statute interpreted in that case.27

*746We can discern no principled reason to limit artificially the principles or logical import of Rowland to the circumstances of that case. Indeed, such a conclusion would be peculiar in all of our jurisprudence — a system of jurisprudence premised on the development of precedents to be followed in similar future cases, thereby ensuring that like cases are treated alike. There is nothing unique about the notice language of the highway exception to governmental immunity that would limit the principle stated in Rowland to the specific facts of that case or the interpretation of that statute. Further, there can be no dispute that the notice provision interpreted in Rowland and the notice provision at issue here, both of which contain bar-to-claims language, are similarly situated. Instead, the principle of Rowland is clear: when the Legislature specifically qualifies the ability to bring a claim against the state or its subdivisions on a plaintiffs meeting certain requirements that the plaintiff fails to meet, no saving construction — such as requiring a defendant to prove actual prejudice — is allowed.

Accordingly, we clarify that Rowland applies to similar statutory notice or filing provisions, such as the one at issue in this case. To the extent that caselaw from the Court of Appeals or statements by individual members of this Court imply or provide otherwise, we disavow them as inconsistent with both the statutes that they sought to interpret and the controlling law of this state as articulated in Rowland.28 Courts may not engraft an *747actual prejudice requirement or otherwise reduce the obligation to comply fully with statutory notice requirements. Filing notice outside the statutorily required notice period does not constitute compliance with the statute.

IV A brief response to the dissent

Contrary to the impression a reader might be left with upon reading the dissent, this case is not a basis to relitigate Rowland. The opinion in Rowland — thorough in its analysis and sound in its logic — speaks for itself, and we need not provide a point-by-point rebuttal to the dissent here where Rowland provided a detailed rebuttal to the same dissenting justice who raised the same unpersuasive arguments there. Although the dissent is entitled to disagree with a precedent of this Court, Rowland is the binding and applicable law, and we faithfully apply it today.

Accordingly, the dissent’s conclusion that plaintiff “sufficiently” complied with the notice requirement of MCL 600.6431 is simply incorrect.29 And the dissent’s *748reasoning that dismissal is not warranted in this case because, in the dissent’s view, defendant suffered no prejudice is legally irrelevant because the Legislature has not included a prejudice component in this statute.

Also noteworthy here is that which the dissent does not dispute. First, the dissent agrees with our reasoning that MCL 600.6431 must be read as a contiguous whole, as well as the resultant conclusion that subsection (3) includes the bar-to-claims language of subsection (1). Indeed, only disagreeing with our ultimate conclusion, the dissent leaves untouched the entirety of this opinion’s textual analysis.30 Second, other than its personal disagreement with the decision of Rowland itself, the dissent does not disagree that Rowland applies to the interpretation of MCL 600.6431. Further, the dissent proffers no reason why the principle of Rowland— which is a binding precedent, like any other decision of this Court — is not entitled to deference and application in similar notice cases pursuant to stare decisis, and the dissent does not contradict our conclusion that Row*749land is not limited to the statute interpreted in that case. For all these reasons, the dissent is entirely unresponsive to the arguments raised in this opinion that compel our conclusions.

A final note on an argument raised by the dissent. The dissent once again relies on the “highly disfavored” theory of legislative acquiescence in support of its conclusion that the Legislature “approved” of the pre-Rowland line of cases instituting a judicially created prejudice requirement. First and foremost, legislative acquiescence has been repeatedly repudiated by this Court because it is as an exceptionally poor indicator of legislative intent.31 When used in a case like this, the theory requires a court to intuit legislative intent not by anything that the Legislature actually enacts, but by the absence of action.32 Yet “a legislature legislates by legislating, not by doing nothing, not by keeping silent.”33 Thus, the doctrine of legislative acquiescence “is a highly disfavored doctrine of statutory construction; sound principles of statutory construction require that *750Michigan courts determine the Legislature’s intent from its words, not from its silence.”34

Notwithstanding these inherent problems with the theory of legislative acquiescence, its use in this case is particularly unavailing. As we explained in Rowland, “[i]n reading an ‘actual prejudice’ requirement into the statute, this Court not only usurped the Legislature’s power but simultaneously made legislative amendment to make what the Legislature wanted — a notice provision with no prejudice requirement — impossible.”35 This reasoning applies with equal force here. As noted earlier, the pre-Rowland cases instituted prejudice requirements for statutory notice provisions on the mistaken belief that those requirements were necessary as a matter of constitutional law. As the dissent is well *751aware, “[Construction of the Constitution is the province of the courts and this Court’s construction of a State constitutional provision is binding on all departments of government, including the legislature.”36 As a result, one can hardly equate the Legislature’s inaction with legislative approval of the pre-Rowland judicial prejudice requirement given that this Court’s pre-Rowland decisions mandated the prejudice requirements for notice provisions lest they be struck down as unconstitutional.37 Thus, the dissent relies on a Catch-22: that the Legislature “acquiesced” in constructions of statutes that this Court deprived it of the power to amend.38 The striking illogic of this argument demands that it once again be repudiated, as it was in Rowland.

V. CONCLUSION

Plaintiffs accident occurred on December 12, 2007. Because her action is for personal injuries, MCL *752600.6431(3) required that she file her claim or a notice of intent to file her claim “with the clerk of the court of claims” within six months, or by June 12, 2008. She did not file notice with the clerk until October 31, 2008. Because plaintiff did not comply with the plain language of the notice filing requirement provided in MCL 600.6431, that statute precludes her from maintaining her claim against the university.

The decision of the Court of Appeals is affirmed.

Markman, Mary Beth Kelly, and Zahra, JJ., concurred with Young, C.J.

Rowland v Washtenaw Co Rd Comm, 477 Mich 197; 731 NW2d 41 (2007).

MCL 600.6431 (emphasis added).

McCahan v Brennan, 291 Mich App 430; 804 NW2d 906 (2011).

Id. at 434-436. The Court specifically noted that “the Michigan Supreme Court overturned several cases that had required the state to show actual prejudice when a plaintiff failed to comply with a statutory filing requirement.” Id. at 434.

Id. at 438 (Fitzgerald, J., dissenting). The dissent would have held that Rowland did not reach the facts of this case because it did not construe the particular statute at issue here, MCL 600.6431. Instead, the dissent would have applied the holding of May v Dep’t of Natural Resources, 140 Mich App 730; 365 NW2d 192 (1985), which requires a showing of actual prejudice before enforcing a mandate that a claim may not be maintained for failure of statutorily required notice. See McCahan, 291 Mich App at 437-438 (Fitzgerald, J., dissenting), quoting and adopting the reasoning of Chief Judge Murphy’s dissenting opinion in Prop & Cas Ins Co of the Hartford v Dep’t of Transp, unpublished opinion per curiam of the Court of Appeals, issued April 22, 2010 (Docket No. 285749) (Murphy, C.J., dissenting).

McCahan v Brennan, 489 Mich 985 (2011).

Maiden v Rozwood, 461 Mich 109, 118; 597 NW2d 817 (1999).

McClements v Ford Motor Co, 473 Mich 373, 380; 702 NW2d 166 (2005).

Sun Valley Foods Co v Ward, 460 Mich 230, 236; 596 NW2d 119 (1999), quoting United States v Turkette, 452 US 576, 593; 101 S Ct 2524; 69 L Ed 2d 246 (1981).

Sun Valley, 460 Mich at 236.

See, generally, MCL 691.1401 et seq.; Rowland, 477 Mich at 202-203.

See Moulter v Grand Rapids, 155 Mich 165, 168-169; 118 NW 919 (1908) (“It being optional with the legislature whether it would confer upon persons injured a right of action therefor or leave them remediless, it could attach to the right conferred any limitations it chose.”); accord Rowland, 477 Mich at 212.

See Sun Valley, 460 Mich at 236-237.

Robinson v City of Lansing, 486 Mich 1; 782 NW2d 171 (2010).

Id. at 14.

Id. at 15.

Id. at 16.

See MCL 600.6419 (providing for exclusive original jurisdiction for claims made against the state).

Notably, plaintiff offers no authority for her interpretation of MCL 600.6431 and, in fact, every case presented by the parties — including those on which plaintiff relies — has interpreted subsection (3) to contain a bar to nonconforming claims. See, e.g., May, 140 Mich App at 731-732 (holding that a plaintiffs claim may be barred by failure to comply with subsection (3) if the defendant shows prejudice). And the dissent in this case also rejects plaintiffs interpretation.

See MCL 691.1404(1).

Rowland, 477 Mich at 201. The Court expressly overruled Hobbs v Dep’t of State Hwys, 398 Mich 90; 247 NW2d 754 (1976), and Brown v Manistee Co Rd Comm,, 452 Mich 354; 550 NW2d 215 (1996), and *744implicitly overruled Carver v McKernan, 390 Mich 96; 211 NW2d 24 (1973), Reich v State Hwy Dep’t, 386 Mich 617; 194 NW2d 700 (1972), and Grubaugh v City of St Johns, 384 Mich 165; 180 NW2d 778 (1970).

Rowland, 477 Mich at 211.

Id. at 210-212.

Notably, the university’s legal office is not a proper party to receive service of process on behalf of the University of Michigan under MCR 2.105(G)(7), let alone to receive notice of a claim governed by MCL 600.6431.

By naming the Clerk of the Court of Claims as the agent for the receipt of verified notice of potential claims, the Legislature has established a clear procedure that eliminates any ambiguity about whether an attempted notice is effective. A claimant who complies with MCL 600.6431 need not worry about whether a notice was properly received and processed by the correct governmental entity. By the same token, state entities can be secure knowing that only timely, verified claims in notices filed with the Court of Claims can give rise to potential liability, that the proper entity as well as the Attorney General will be notified, and that only such claims need to be investigated in anticipation of potential litigation.

See MCL 691.1404(1) (“As a condition to any recovery for injuries sustained by reason of any defective highway, the injured person, within 120 days from the time the injury occurred, except as otherwise provided in subsection (3) shall serve a notice on the governmental agency of the occurrence of the injury and the defect.”).

In addition to the instant case, see, e.g., Kline v Dep’t of Transp, 291 Mich App 651; 809 NW2d 392 (2011); Prop & Cas Ins Co of the Hartford v Dep’t of Transp, unpublished opinion per curiam of the Court of Appeals, issued April 22, 2010 (Docket No. 285749).

See Beasely v Michigan, 483 Mich 1025 (2009) (Marilyn Kelly, C.J., concurring); Ward v Mich State Univ, 485 Mich 917 (2009) (Marilyn *746Kelly, C.J., concurring); see also Chambers v Wayne Co Airport Auth, 482 Mich 1136 (2008) (Cavanagh, J., dissenting).

We specifically note May, 140 Mich App 730, upon which the Court of Appeals dissent and plaintiff primarily rely. May, 140 Mich App at 731-732, grounded its holding that MCL 600.6431 was only constitutional if the governmental agency involved was required to show actual prejudice in large part on Carver, 390 Mich 96, and a Court of Appeals decision *747that also relied on Carver, Hanger v State Hwy Dep’t, 64 Mich App 572; 236 NW2d 148 (1975). As noted earlier, Rowland implicitly overruled Carver, as well as expressly overruled the progeny of Carver, including Hobbs and Brown, all of which formed the basis for the pre-Rowland prejudice rule.

Given that this Court has overruled the decisions on which May was based, it should be reasonably clear that May, too, no longer remains good law for those propositions that have been overruled in the cases on which May relied.

The dissent itself concedes that plaintiff failed to provide the required statutory notice. However, the dissent has simply decided against applying the Legislature’s designated consequence for such a failure.

Curiously, the dissent characterizes this opinion as requiring that “MCL 600.6431 must be strictly enforced” and thus plaintiffs failure to provide notice to defendant “that complied in every detail with the statute requires that her entire claim be dismissed.” Post at 752. We are *748at a loss why such a charge makes sense when we are merely giving the plain meaning to the words used by the Legislature. What we do here is not “strict enforcement” of the notice provision, but what any Court must do: give a reasonable interpretation to the language that the Legislature has passed and the Governor has signed into law. We find nothing “strict,” as opposed to being merely reasonable, in concluding that “six months” means “six months,” “files in the office of the clerk” means “files in the office of the clerk,” and “in detail” means “in detail.” Our view is that the rule of law requires that courts of this state must respect the legislative policy choices as expressed in the language of the statutes that come before them.

Strangely enough, even though this case is one of statutory construction, the dissent undertakes no effort whatsoever to interpret the actual words of the statute that we are charged with interpreting, instead relying on a nonexistent prejudice requirement in support of its conclusion. The dissent’s argument that this conclusion satisfies the intent of the Legislature is, of course, belied by the actual words chosen by the Legislature.

See, e.g., Rowland, 477 Mich at 209 n 8; Donajkowski v Alpena Power Co, 460 Mich 243, 258-261; 596 NW2d 574 (1999), quoting Rogers v Detroit, 457 Mich 125, 163-166; 579 NW2d 840 (1998) (Taylor, J., dissenting); Autio v Proksch Constr Co, 377 Mich 517, 527-539; 141 NW2d 81 (1966); Van Dorpel v Haven-Busch Co, 350 Mich 135, 145-149; 85 NW2d 97 (1957), quoting in part Sheppard v Mich Nat’l Bank, 348 Mich 577, 599; 83 NW2d 614 (1957) (Smith, J., concurring).

The dissent’s own language demonstrates how amorphous and unprincipled the theory of legislative acquiescence is. The dissent reasons that “ ‘[tjhere was the possibility of change. Because it did not occur, it is reasonable to deduce that the Legislature’s inaction has been intentional.’” Post at 756, quoting Rowland, 477 Mich at 263 (Marilyn Kelly, J., concurring in part and dissenting in part). We find nothing whatsoever reasonable about this “deduction” that the failure to act on a mere “possibility” of change necessarily equates to affirmative approval. See Donajkowski, 460 Mich at 259-260 (setting forth more than a dozen reasons why a legislature may fail to correct an erroneous judicial decision).

Wycko v Gnodtke, 361 Mich 331, 338; 105 NW2d 118 (1960).

Donajkowski, 460 Mich at 261.

Notably, the dissent ascribes no significance to the fact that Rowland has been the law of this state for approximately five years, and in that time the Legislature has not acted to add prejudice requirements to various statutory notice provisions. Apparently for the dissent, the Legislature’s alleged acquiescence in the decisions overruled by Rowland is deserving of greater deference here than any current “acquiescence” in the governing construction. Compare also People v Lown, 488 Mich 242; 794 NW2d 9 (2011) (Marilyn Kelly, J., dissenting), in which the dissenting justice argued that the Court should overrule a 1959 decision of this Court interpreting MCL 780.131 and MCL 780.133 without any mention or apparent regard of more than 50 years of legislative “acquiescence” in that decision. We are unclear what principle demarcates when the theory should be selectively employed as dispositive of legislative intent in one case but not another, and the dissent does not take this opportunity to elucidate. Cf. Paige v Sterling Hts, 476 Mich 495, 516-518; 720 NW2d 219 (2006) (criticizing the dissent’s “undeniably inconsistent” use of legislative acquiescence); Autio, 377 Mich at 527-539 (criticizing the “selective invocation” of legislative acquiescence). Indeed, the theory appears to be employed in certain quarters primarily as “another way of sustaining forever any precedent, no matter how wrongly decided,” Robertson v DaimlerChrysler Corp, 465 Mich 732, 760 n 15; 641 NW2d 567 (2002), and in this regard it is truly “a pernicious evil designed to relieve a court of its duty of self-correction,” Autio, 377 Mich at 527.

Rowland, 477 Mich at 213 (emphasis added).

Richardson v Secretary of State, 381 Mich 304, 309; 160 NW2d 883 (1968).

The dissent nevertheless persists in this argument, curiously asserting that “the Legislature could have amended notice requirements in conformity with Hobbs and Brown and chose not to do so.” Post at 761. Yet it would be more than passing strange for the Legislature to amend notice statutes “in conformity with Hobbs and Brown” if the amendments that the Legislature wanted were the opposite of what would have been constitutionally permitted by those cases.

The dissent bemoans the fact that we criticize its use of legislative acquiescence, asserting that “tj]udges are free to pick and choose the interpretive tools with which they engage in statutory interpretation.” Post at 757 n 22. Whatever the merits of this argument, where our dissenting colleague can provide no generalized theory that allows one to predict when she will or will not invoke legislative acquiescence, it is perfectly appropriate to highlight the problems with the dissenting justice’s methodology of deciding cases. Not all methods of interpretation are of equal value, and highlighting the problems seems particularly appropriate when the method employed results in a construction that is contrary to clear statutory language, as is the case here.