Auto-Owners Insurance Company, Petitioner Vs. Township Of Delta, Respondent

Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 

Auto-Owners Insurance Company, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002141 

 

Delta Township, 

 

Presiding Judge 

Respondent. 

 

Jason C. Grinnell 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, 

 

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all 

attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise 

indicated. 

 

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment 

rolls for the tax years at issue shall correct or cause the assessment rolls to be 

corrected to reflect the property’s true cash and taxable values as provided in this 

Consent Judgment within 20 days of the entry of the Consent Judgment.2 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund as 

required by the Consent Judgment within 28 days of the entry of the Consent 

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a 

proportionate share of any property tax administration fees paid and of penalty and 

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, 

separately indicate the amount of the taxes, fees, penalties, and interest being 

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless 

otherwise indicated, bear interest from the date of payment to the date of judgment and 

the judgment shall bear interest to the date of its payment. A sum determined by the 

Tribunal to have been underpaid shall not bear interest for any time period prior to 28 

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest 

shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-002141 

Page 2 of 2 

 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, and (xviii) after June 30, 2025, through December 31, 2025, at the rate of 

8.66%. 

 

This Consent Judgment resolves all pending claims in this matter and closes this case. 

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

 

 

 

 

 

 

By _______________________________ 

Entered: November 4, 2025 

am 

 

PROOF OF SERVICE 

 

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

 

By: Tribunal Clerk

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Page 1

62306709.2

STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

Auto-Owners Insurance Company,

Petitioner,

v

Delta Charter Township,

Respondent.

MTT Docket No. 25-002141

_____________________________________________________________________________/

Stewart L. Mandell (P33781)

Daniel L. Stanley (P57052)

Honigman LLP

Attorneys for Petitioner

39400 Woodward Ave., Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

dstanley@honigman.com

Laura M. Hallahan (P42101)

Seth A. O’Loughlin (P80257)

Kelsea M. Melcher (P85821)

Hallahan & Associates, P.C.

Attorneys for Respondent

1750 S. Telegraph Rd., Suite 202

Bloomfield Hills, MI 48302

(248) 731-3089

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

_____________________________________________________________________________/

Stipulation for Entry of Consent Judgment

1.

The parcel is located in Eaton County.

2.

The case is pending in the X Entire Tribunal OR __ Small Claims Division.

3.

Property Parcel No. 23-040-023-300-050-01.

4.

The values for the property identified above as established by Respondent’s Board of

Review are:

Tax Year

True Cash Value

Assessed Value

Taxable Value

2025

$20,661,000

$10,330,500

$10,330,500

5.

The values for the property identified above as stipulated by the parties for settlement

purposes are:

Tax Year

True Cash Value

Assessed Value

Taxable Value

2025

$19,320,000

$9,660,000

$9,660,000

Page 2

MTT Docket No. 25-002141

Stipulation for Entry of Consent Judgment

2

62306709.2

6.

If stipulation addresses tax years other than the tax year originally appealed or tax years

added through motions to amend that have been granted by the Tribunal, list the separate

facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or

years (attach additional page if necessary):

7.

List separately any special terms or conditions being proposed by the parties that would

affect the execution of this Consent Judgment including, but not limited to, the joint

payment of the refund, the waiver of interest, etc.:

IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be

made payable to Petitioner named herein, and sent to Auto-Owners

Insurance Company, Attn: Dan Keefe, PO Box 30660, Lansing, MI

48909. Calculations of the refund amount also shall be sent to the same

address.

All interest due on any refund is waived if, and only if, all refunds

otherwise due are paid within 60 days of the entry of the consent

judgment, however, otherwise interest shall be paid as provided in the

Tax Tribunal Act, including MCL 205.737.

Honigman LLP

Hallahan & Associates, P.C.

Attorneys for Petitioner

Attorneys for Respondent

By: /s/ Stewart L. Mandell

By:/s/ Seth A. O’Loughlin

Stewart L. Mandell (P33781)

Daniel L. Stanley (P57052)

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

dstanley@honigman.com

Laura M. Hallahan (P42101)

Seth A. O’Loughlin (P80257)

Kelsea M. Melcher (P85821)

1750 S. Telegraph Road, Suite 202

Bloomfield Hills, MI 48302

(248) 731-3087

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Dated: October 29, 2025

Dated: October 29, 2025

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Page 1

62306709.2

STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

Auto-Owners Insurance Company,

Petitioner,

v

Delta Charter Township,

Respondent.

MTT Docket No. 25-002141

_____________________________________________________________________________/

Stewart L. Mandell (P33781)

Daniel L. Stanley (P57052)

Honigman LLP

Attorneys for Petitioner

39400 Woodward Ave., Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

dstanley@honigman.com

Laura M. Hallahan (P42101)

Seth A. O’Loughlin (P80257)

Kelsea M. Melcher (P85821)

Hallahan & Associates, P.C.

Attorneys for Respondent

1750 S. Telegraph Rd., Suite 202

Bloomfield Hills, MI 48302

(248) 731-3089

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

_____________________________________________________________________________/

Stipulation for Entry of Consent Judgment

1.

The parcel is located in Eaton County.

2.

The case is pending in the X Entire Tribunal OR __ Small Claims Division.

3.

Property Parcel No. 23-040-023-300-050-01.

4.

The values for the property identified above as established by Respondent’s Board of

Review are:

Tax Year

True Cash Value

Assessed Value

Taxable Value

2025

$20,661,000

$10,330,500

$10,330,500

5.

The values for the property identified above as stipulated by the parties for settlement

purposes are:

Tax Year

True Cash Value

Assessed Value

Taxable Value

2025

$19,320,000

$9,660,000

$9,660,000

Page 2

MTT Docket No. 25-002141

Stipulation for Entry of Consent Judgment

2

62306709.2

6.

If stipulation addresses tax years other than the tax year originally appealed or tax years

added through motions to amend that have been granted by the Tribunal, list the separate

facts upon which the parties rely to invoke the Tribunal’s authority over those tax year or

years (attach additional page if necessary):

7.

List separately any special terms or conditions being proposed by the parties that would

affect the execution of this Consent Judgment including, but not limited to, the joint

payment of the refund, the waiver of interest, etc.:

IT IS FURTHER ORDERED AND ADJUDGED that refunds shall be

made payable to Petitioner named herein, and sent to Auto-Owners

Insurance Company, Attn: Dan Keefe, PO Box 30660, Lansing, MI

48909. Calculations of the refund amount also shall be sent to the same

address.

All interest due on any refund is waived if, and only if, all refunds

otherwise due are paid within 60 days of the entry of the consent

judgment, however, otherwise interest shall be paid as provided in the

Tax Tribunal Act, including MCL 205.737.

Honigman LLP

Hallahan & Associates, P.C.

Attorneys for Petitioner

Attorneys for Respondent

By: /s/ Stewart L. Mandell

By:/s/ Seth A. O’Loughlin

Stewart L. Mandell (P33781)

Daniel L. Stanley (P57052)

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

dstanley@honigman.com

Laura M. Hallahan (P42101)

Seth A. O’Loughlin (P80257)

Kelsea M. Melcher (P85821)

1750 S. Telegraph Road, Suite 202

Bloomfield Hills, MI 48302

(248) 731-3087

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Dated: October 29, 2025

Dated: October 29, 2025

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

AUTO-OWNERS INSURANCE COMPANY, 

 

 

 

Petitioner, 

 

v 

 

TOWNSHIP OF DELTA, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002141 

 

 

_____________________________________________________________________________/ 

 

STEWART L. MANDELL (P33781) 

HONIGMAN LLP 

Attorney for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, Township of Delta, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent lacks the information necessary to respond to the allegations in 

Paragraph 1 and leaves Petitioner to its proofs. 

2. 

Respondent admits the allegations in Paragraph 2 insofar as it is the entity that 

assesses and collects property taxes with relation to the parcel identified in the Petition. 

3. 

Respondent admits the allegations in Paragraph 3 as to the stated values.

Page 2

2

4. 

Respondent admits that subject property is classified as commercial improved. 

With respect to the remaining allegations in Paragraph 4, Respondent lacks knowledge or 

information sufficient to form a belief as to the truth of the allegations contained therein and leaves 

Petitioner to its proofs. 

5. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 5 but denies 

Petitioner’s claims have merit. 

6. 

Respondent denies the allegations in Paragraph 6. 

7. 

Respondent neither admits nor denies the allegations in Paragraph 7 as the General 

Property Tax Act and the Tribunal’s jurisdiction speak for themselves. 

8. 

Respondent denies the allegations in Paragraph 8, including subparagraphs (a)-(d), 

for the reason that the same are untrue. In further answer, the assessed, state equalized and/or 

taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value 

permitted by law, were correctly determined and are based upon correct application of proper 

principles, and the values and Respondent’s mode of assessment are non-discriminatory and 

constitutional. 

9. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of the Petition but denies that Petitioner is entitled to the requested relief due to the statements in 

the above Paragraphs. 

WHEREFORE, Respondent, Township of Delta, requests the Tribunal dismiss the Petition, 

affirm Respondent’s assessed and taxable values, subject to county and state equalization, and 

award Respondent its costs and attorney fees.

Page 3

3

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan________________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: August 26, 2025 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, Township of Delta, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the

Page 4

4

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

10. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

11. 

Respondent has properly and lawfully assessed Petitioner’s property and 

established its taxable value in accordance with statutory and constitutional requirements. 

12. 

Petitioner has failed to pursue its appeal in a timely fashion. 

13. 

Respondent reserves the right to raise additional affirmative defenses as the same 

may become known to it during the course of these proceedings. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield

Page 5

5

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-002141

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Delta (EATON)

Local Unit of Government/First Name

M.I.

Last Name

Home Address (No., Street, P.O. Box or Rural Route)

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

Address (No., Street, P.O. Box or Rural Route)

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48302

Telephone Number

248-731-3087

Fax Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

MTT@hallahanlaw.com

Electronic Signature *Typing your name below will serve as your signature

Respondent or Authorized Attorney/Representative’s Signature: 

Laura M Hallahan

/s/

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Page 1

RECEIVED 

Wo 

JUN 06 2025 

Yc 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Auto-Owners Insurance Company, 

Petitioner, 

MTT Docket No. es OJ / of ( 

ve 

Parcel No. 23-040-023-300-050-01 

Delta Township, 

Respondent. 

Stewart L. Mandell (P33781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

dlstanley@honigman.com 

/ 

Proof 

of Service 

Lisa Joseph states that on 

le / 

3 / xS 

, she did serve a copy of Petitioner's Petition, 

with docket number, upon the parties named on the attached list. 

Dated: 

( 

/ 5 / Ci 

[5 

Jie 

raced,

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

DELTA TWP. 

7710 W. SAGINAW HWY. 

LANSING, MI 48917 

ASSESSOR 

DELTA TWP. 

7710 W. SAGINAW HWY. 

LANSING, MI 48917 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

EATON COUNTY 

1045 INDEPENDENCE BLVD. 

CHARLOTTE, MI 48813-1033 

DIRECTOR OF EQUALIZATION 

EATON COUNTY 

1045 INDEPENDENCE BLVD. 

CHARLOTTE, M1 48813-1033 

SECRETARY OF SCHOOL BOARD 

WAVERLY COMMUNITY SCHOOLS (EATON) 

515 SNOW ROAD 

LANSING, MI 48917-4502 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0108

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Page 1

25-0029 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Auto-Owners Insurance Company, 

Petitioner, 

v. 

Delta Township, 

Respondent. 

MTT Docket No. ________ 

Parcel No. 23-040-023-300-050-01 

Stewart L. Mandell (P33781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

dlstanley@honigman.com

Petition 

Auto-Owners Insurance Company (“Petitioner”), through its attorneys, Honigman LLP, 

says: 

1.

Petitioner's principal office address is 6101 Annacapri Blvd., Lansing, MI 48909. 

Petitioner is a party in interest with respect to property taxes on tax parcel number 23-040-023-

300-050-01 ("Petitioner's Property"), with an address of 6190 South Campus Blvd., Delta 

Township, located in Eaton County, Michigan. 

2.

Respondent, Delta Twp., assesses and collects property taxes on Petitioner's 

Property.

Page 2

2 

60721595.1 

3.

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$10,330,500 and assessed Petitioner's Property at $10,330,500, which will result in a state 

equalized value in the same amount based upon the tentative equalization factor. 

4.

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, and (d) due process, equal protection and uniformity. 

6.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7.

No board of review protest was required for Petitioner’s Property. 

8.

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, is 

based upon an erroneous determination of the true cash value of that portion of Petitioner's 

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and

Page 3

3 

60721595.1 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 assessed value, state equalized value, and taxable value of Petitioner's Property from 

$10,330,500 to $5,590,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: May 31, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

dlstanley@honigman.com

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

Auto-Owners Insurance Company, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002141

Township Of Delta, 

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted 

docket number has been assigned to that petition. This docket number shall be noted 

on the petition and the petition shall be served within 45 days of the issuance of 

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served 

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the 

issuance of this notice evidencing the service of the petition. 

If you submitted a proof of service with the petition, you must still serve the petition and 

file a second proof of service including the docket number, pursuant to this notice. 

Failure to serve the petition and file a proof of service within 45 days of the issuance of 

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28 

days after the date of service of the petition with noted docket number.” Failure to do so 

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this 

case. Further, the assignment of the docket number does not mean that the Tribunal 

has authority over the petition or that the petition complies with statutory requirements 

or the Tribunal’s rules.

By: __Tribunal Clerk________

Entered: August 13, 2025

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

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Page 1

25-0029 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Auto-Owners Insurance Company, 

Petitioner, 

v. 

Delta Township, 

Respondent. 

MTT Docket No. ________ 

Parcel No. 23-040-023-300-050-01 

Stewart L. Mandell (P33781) 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

dlstanley@honigman.com

Petition 

Auto-Owners Insurance Company (“Petitioner”), through its attorneys, Honigman LLP, 

says: 

1.

Petitioner's principal office address is 6101 Annacapri Blvd., Lansing, MI 48909. 

Petitioner is a party in interest with respect to property taxes on tax parcel number 23-040-023-

300-050-01 ("Petitioner's Property"), with an address of 6190 South Campus Blvd., Delta 

Township, located in Eaton County, Michigan. 

2.

Respondent, Delta Twp., assesses and collects property taxes on Petitioner's 

Property.

Page 2

2 

60721595.1 

3.

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$10,330,500 and assessed Petitioner's Property at $10,330,500, which will result in a state 

equalized value in the same amount based upon the tentative equalization factor. 

4.

Petitioner's Property is classified as commercial improved. Petitioner's Property is 

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's 

Property was originally designed to be used for commercial purposes. 

5.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable 

value, and (d) due process, equal protection and uniformity. 

6.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

7.

No board of review protest was required for Petitioner’s Property. 

8.

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful 

for the reasons that: 

(a) 

The assessment, including state equalized value and/or taxable value, 

exceeds the amount permitted by the Michigan Constitution and applicable statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, is at 

a higher percentage of true cash value than permissible under the Michigan Constitution and 

applicable statutes; 

(c) 

The assessment, including taxable value and/or state equalized value, is 

based upon an erroneous determination of the true cash value of that portion of Petitioner's 

Property that is taxable under Michigan law, and is based upon the application of wrong principles; 

and

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60721595.1 

(d) 

The assessment, including state equalized value and/or taxable value, and 

the mode of assessment adopted by Respondent, discriminate against Petitioner and deny 

Petitioner its constitutional rights to uniformity, equal protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 assessed value, state equalized value, and taxable value of Petitioner's Property from 

$10,330,500 to $5,590,000; (ii) requiring payment to Petitioner of the refunds attributable to such 

reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is 

entitled. 

Dated: May 31, 2025

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By:

Stewart L. Mandell (P33781) 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com

dlstanley@honigman.com

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Auto-Owners Insurance Company

Home Address (No., Street, P.O. Box or Rural Route)

6101 Annacapri Blvd.

City or Town

Lansing

State

Michigan

ZIP Code

48909

Telephone Number

2485668300

Fax Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Stewart

M.I.

Last Name

Mandell

Firm Name (if any)

Honigman LLP

Address (No., Street, P.O. Box or Rural Route)

2290 First National Building

660 Woodward Avenue

City or Town

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-465-7420

Fax Number

313-465-7421

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

slmandell@honigman.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

Michigan

Taxing Authority (City or Township)

Township Of Delta (EATON)

County

Eaton

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

23-040-023-300-050-01

Classification of Property: Real 

Commercial

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

10330500

Current Taxable Value as established by the Board of Review:

10300500

What do you believe is the fair market value (also known as True Cash Value)?

11180000

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

5590000

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the highest 

State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

Electronic Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Stewart L. Mandell

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.