
Michigan decided by statute who loses an argument about a typo. Under MCL 8.47(3), once the Michigan Compiled Laws and the Michigan Administrative Code have been designated official, they are the official statutes and administrative rules of the state and evidence in every court with jurisdiction, and anyone contesting the accuracy of a compilation carries the burden of proving by a preponderance of the evidence that it is inaccurate.
So the published text starts ahead. If you think the compiler dropped a word, you get to prove it.
Two offices, two designations
The same section splits the job. The Legislative Council examines the electronic compilation of the Michigan Compiled Laws and designates it official, then after the final adjournment of each even-year regular session authenticates that the compilation is an accurate copy of the general laws in force through the end of that session. The Michigan Administrative Code goes through a different door: the office of performance and transformation examines it and designates the electronic compilation official before it reaches the public.
That wording arrived with 2018 PA 655, effective March 29, 2019. It matters because the older habit of treating print as the authority is still written down in places. The Supreme Court's own opinion manual, last revised in December 2017, tells editors the official version of a current Michigan law is the one published in the 1979 Compiled Laws, or for anything enacted or amended later, the Public and Local Acts volume or the enrolled bill filed with the Secretary of State. Both statements were true when written. Only one of them describes what a court will now take as evidence.
Michigan writes citations without periods
The Office of the Reporter of Decisions publishes the Michigan Appellate Opinion Manual, and it sets the house style for Supreme Court and Court of Appeals opinions. Statutes get no section symbol and no periods. Reporter abbreviations get no periods either, and the spacing depends on how many letters abbreviate each word:
Statute MCL 776.20
Range MCL 750.1 through MCL 750.568
Administrative Mich Admin Code, R 408.41863
Prior version 1983 Annual Admin Code Supp, R 408.41863
Register 2017 Mich Reg 1 (February 1, 2017), p 80
Constitution Const 1963, art 6, § 1
Case Badeen v Par, Inc, 300 Mich App 430; 834 NW2d 85 (2013)
Three of those rows catch people out. The constitution cite carries the year of the constitution and no state name, and the year is the constitution's year even where the section has been amended since. "MCL" has to be repeated across a range, so MCL 769.1 through MCL 769.36 is right and a hyphen is wrong. And parallel citations are divided by a semicolon, which is where a copied citation usually gives itself away. When a string of cases is joined by the word "and", the separator flips to a comma instead.
The official reports are the Michigan Reports and the Michigan Appeals Reports, abbreviated Mich and Mich App. The regional reporter cite is the parallel one.
The number in the cite is a compilation number
Here is the thing that produces wrong pinpoints. An MCL number is assigned by the compiler, and the section number inside the act is assigned by the Legislature. They usually agree in a readable way. Sometimes they don't.
The manual works through MCL 257.625k. That provision lives in the Michigan Vehicle Code, 1949 PA 300, compiled into Chapter 257, and it is section 625k of the act. Fine. Now take MCL 208.1433. That is section 433 of 2007 PA 36, because the compiler in that chapter chose to leave the 400s alone. Calling it section 1433 would be wrong. Some statutes skip subsection numbering entirely and drop straight to subdivisions, as MCL 37.1103(d)(i)(d) does.
The safe habit the reporter's office recommends is to use the full compilation citation even in running text.
Two more things are outside the statute even though they sit on the page with it. Catchlines that follow the act section number were legislatively deemed not to be part of the section by MCL 8.4b, so they cannot widen or narrow the text and should stay out of a quotation. Court rule catchlines get the same treatment under MCR 1.106. Statutory history lines and the boldface headings added by annotated services are editorial and belong outside your quotation marks too.
A worked example, and an old brief
Somebody hands you a 1996 Michigan brief with a line like this one.
Defendant was charged with first-degree murder, MCL 750.316; MSA 28.548
Two numbers, one crime. The second belongs to an annotated numbering scheme that ran alongside the compilation for decades, and a lookup against today's Michigan Compiled Laws on that number returns nothing.
Take the first number. MCL 750.316 is in Chapter 750, the Michigan Penal Code, 1931 PA 328, which runs MCL 750.1 through MCL 750.568. Check it on the electronic compilation, since that is what MCL 8.47(3) now makes evidence. Then drop the second number: the opinion manual expressly permits omitting the paired citation from a quotation, using a note that a citation was omitted, with no ellipsis and no brackets.
Would you have spotted that the paired number was a whole separate numbering scheme? Plenty of people read it as a subsection.
What will bite you
Michigan's statute book barely moves. Its rule book moves constantly. Of 42,354 statute sections, 42,349 are in force. Of 22,148 administrative rule sections, 16,170 are in force, 5,749 are repealed and 222 were rescinded. Almost all of the churn in Michigan law sits on the regulatory side, so a stale statute cite is rare and a stale rule cite is ordinary.
And when you cite a rule, write it the way the code does. Mich Admin Code, R 408.41863 has a comma after Code and a bare R before the number. Shorten it later to Rule 408.41863.
Facts used
All Michigan corpus counts below are from Vaquill AI's US primary law data.
| Claim | Value | Where from |
|---|---|---|
| Statute sections | 42,354 (42,349 in force, 3 reserved, 2 repealed) | Corpus status counts |
| Regulation sections | 22,148 (16,170 in force, 5,749 repealed, 222 rescinded, 6 reserved, 1 expired) | Corpus status counts |
| Court rule sections | 1,025 (946 in force, 79 repealed) | Corpus status counts |
| Constitution sections | 275 | Corpus counts |
| All Michigan sections held | 65,953 | Corpus counts |
| Whoever contests a compilation's accuracy bears the burden by a preponderance | MCL 8.47(3) | Published section text |
| Legislative Council designates the electronic MCL official and authenticates after each even-year session | MCL 8.47(1) | Published section text |
| The office of performance and transformation designates the Michigan Administrative Code official | MCL 8.47(2) | Published section text |
| Current wording added by 2018 PA 655, effective March 29, 2019 | Verified | History line on MCL 8.47 |
| Opinion manual points to the 1979 Compiled Laws, Public and Local Acts, or the enrolled bill | Verified | Michigan Appellate Opinion Manual, revised December 2017, § 2:4.5 |
| Cite statutes as MCL with no periods and no section symbol | Verified | Same manual, § 1:21.1 |
| "MCL" repeats across a range, and hyphens are not used | Verified | Same manual, § 1:21.1 |
| No periods in reporter abbreviations, spacing set by letter count | Verified | Same manual, § 1:8 |
| Parallel citations separated by semicolons, commas when joined by "and" | Verified | Same manual, § 1:9.1 |
| Constitution cited as Const 1963, art 6, § 1, with no state name | Verified | Same manual, § 1:20 |
| Administrative rules cited as Mich Admin Code, R 408.41863 | Verified | Same manual, § 1:23.10 |
| MCL 257.625k is § 625k of 1949 PA 300, but MCL 208.1433 is § 433 of 2007 PA 36 | Verified | Same manual, § 1:21.1 |
| Catchlines following the act section number are not part of the statute | MCL 8.4b | Published section text |
| Court rule catchlines are not part of the rule | MCR 1.106 | Same manual, § 2:4.6 |
| A paired MSA citation may be dropped from a quotation with a citation-omitted note | Verified | Same manual, quotation chapter |
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Priyansh leads engineering and AI at Vaquill, from the matter workbench to drafting, document comparison, document matrix, and citation-verified research.