Richard Miller v. Michigan Department of Corrections

Summary

The Michigan Supreme Court held that the Elliott-Larsen Civil Rights Act permits associational or third-party retaliation claims under MCL 37.2701(a), even when the plaintiff did not personally engage in protected conduct. Plaintiffs sufficiently alleged adverse employment actions, a causal connection to Cedric Griffey's protected activity, and resulting damages, so their claims were legally sufficient at the pleading stage. The Court rejected the Court of Appeals' conclusion that MCL 37.2701(f) exclusively governs such claims and reversed and remanded. No separate opinions were filed.