Brown v. Manistee County Road Commission

Neff, P.J.,

(dissenting). I respectfully dissent and would hold that plaintiffs claim is not barred by MCL 224.21; MSA 9.121.

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In my view, the broad language of MCL 691.1404(1); MSA 3.996(104)(1) preempts application of the sixty-day provision in MCL 224.21; MSA 9.121. MCL 691.1404(1); MSA 3.996(104X1) provides in pertinent part:

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 provided in subsection (3) shall serve a notice on the governmental agency of the occurrence of the injury and the defect. [Emphasis added.]

The first criterion in determining the intent of the Legislature is the specific language of the statute. House Speaker v State Administrative Bd, 441 Mich 547, 567; 495 NW2d 539 (1993). Words in *579a statute are to be accorded their plain and ordinary meaning. MCL 8.3a; MSA 2.212(1). I believe that the words emphasized in the above-quoted portion of the statute serve to override the sixty-day notice provision regarding boards of county road commissioners in MCL 224.21; MSA 9.121.

Further, the sixty-day notice provision has not been applied in any reported cases involving county road commissions since MCL 691.1404; MSA 3.996(104) was amended in 1970. Until that provision was amended by 1970 PA 155, it also contained a sixty-day notice provision. The amendment changed it to 120 days. There is no apparent reason for changing the notice provision regarding governmental agencies other than county road commissions, but not that of the road commissions.

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Even if I agreed that the Legislature intended that there be a shorter notice period for county road commissions than for other governmental agencies, I would hold that such a legislative scheme violates equal protection guarantees. US Const, Am XIV; Const 1963, art 1, § 2. Those guarantees are violated where the legislative classification is arbitrary and not rationally related to the object of the legislation. Bissell v Kommareddi, 202 Mich App 578, 580; 509 NW2d 542 (1993).

The purpose of the provisions requiring notice to governmental bodies of injuries on highways is to provide the governmental agency with an opportunity to investigate the claim while the evidentiary trail is still fresh and to remedy the defect before others are injured. Hussey v Muskegon Heights, 36 Mich App 264, 267-268; 193 NW2d 421 (1971).

The legislation here at issue arbitrarily splits the class of those persons suing governmental *580agencies for injuries resulting from defective highways into two differently treated classes: those suing county road commissions, who are required to file notice of a claim within sixty days of an injury, and those suing other governmental agencies, who are required to give 120 days’ notice of an injury. The differing treatment of those two classes of plaintiffs bears no rational relationship to the recognized purpose of the enactments. I can surmise no rational reason for requiring a shorter notice period to county road commissions than to the state highway department, for instance. The legislative classification therefore violates constitutional guarantees of equal protection. On that basis, I would hold that plaintiff’s claim is not barred.