Record Finder / 25-002274-TT
Michigan

Meijer Inc, Petitioner Vs. City Of Fremont, Respondent

Petitioner
Meijer Inc
Respondent
City Of Fremont

Case overview

Docket number
25-002274-TT
Status
Abeyance
CaseType
ET Property
Division
ET
County
Newaygo
Judge
No judge assigned

Docket history

Line #SubjectFilerLine RefEnter Date/Post MarkFeeRelated Item
10A response to motion was filed.Not recordedNot recorded06/11/2026Not recordedDownload
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
9Motion to Amend Subsequent Year was received.PETNot recorded05/21/2026$300.00Download
Not recordedNot recordedNot recordedNot recordedNot recordedNot recordedDownload
8GrantedPET609/23/2025Not recordedDownload
7Order granting Motion.Not recorded609/23/2025Not recordedDownload
6Motion for Abeyance was received.PETNot recorded09/18/2025$50.00Download
5Answer was receivedRESPNot recorded07/10/2025Not recordedDownload
4Proof of service of petition was received.PETNot recorded06/11/2025Not recordedDownload
3Notice of Docket Number ETNot recordedNot recorded06/16/2025Not recordedDownload
2A petition has been filed.PETNot recorded06/09/2025Not recordedDownload
1Order Severing 2025 Tax Year from 24-003106Not recordedNot recorded06/05/2025Not recordedDownload

Documents

MTA 2026 Response_Meijer Fremont_FINAL.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Meijer, Inc., 

 

 

 

Petitioner, 

 

v 

 

City of Fremont, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002274 

 

 

 

_____________________________________________________________________________/ 

 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorney for Petitioner 

22 North Washington Square, Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

MARK C. MILLER (P68609) 

MURPHY CARIS & MILLER, P.C. 

Attorney for Respondent 

20 E. Main Street 

Fremont, MI 49412 

(231) 924-2226 

 

 

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 

_____________________________________________________________________________/ 

 

 

RESPONDENT’S RESPONSE TO PETITIONER’S MOTION TO AMEND 

PETITION TO CONTEST 2026 ASSESSED AND TAXABLE VALUES 

 

Respondent, City of Fremont, by and through its attorneys, Hallahan & Associates, P.C., 

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

1. 

Respondent admits the allegations in Paragraph 1. 

2. 

Respondent denies the allegations in Paragraph 2, including subparagraphs (a)-(d), 

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

Page 2

2

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. 

3. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

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

the above paragraphs. Respondent incorporates by reference the affirmative defenses set forth in 

its Answer to Petition herein. 

WHEREFORE, Respondent, City of Fremont, requests the Tribunal enter an Order 

denying Petitioner’s Motion to Amend and dismissing the appeal. 

 

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: June 11, 2026 

(248) 731-3089

Page 3

3

 

PROOF OF MAILING 

 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Response to 

Petitioner’s Motion to Amend to: 

 

Daniel L. Stanley 

Honigman LLP 

dstanley@honigman.com 

 

I declare that the statement above is true to the best of my information, knowledge and belief. 

 

 

 

/s/ Kelsea Melcher____________ 

Dated: June 11, 2026 

Kelsea Melcher

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Page 1

1 of 1

Docket #: 25-002274

Party Filing Document

Party Filing Document: 

 Respondent

 Respondent

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Meijer v Fremont - Motion to Amend 2026 (25-002274).pdfRead complete document text →
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Page 1

75658477.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Meijer, Inc., 

Petitioner, 

v. 

Fremont, 

Respondent. 

/

MTT Docket No. 25-002274 

Daniel L. Stanley (P57052) 

Honigman LLP 

Attorneys for Petitioner 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

Mark C. Miller (P68609) 

Murphy Caris & Miller, P.C. 

Attorneys for Respondent 

20 E. Main Street 

Fremont, MI 49412 

(231) 924-2226 

mark@murphycarismiller.com

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 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

/

Motion to Amend Petition to Contest 

2026 Assessed and Taxable Values 

Petitioner, Meijer, Inc., through its attorneys, Honigman LLP, moves to amend the Petition 

in this matter to include the following:

Page 2

2 

75658477.1 

1.

In 2026, Respondent determined the taxable value of Petitioner’s Property 

to be $4,219,000 and Respondent assessed Petitioner’s Property at $4,219,000, which will result 

in a state equalized value of the same amount, based upon the tentative equalization factor. 

2.

The 2026 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 amounts 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 

(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 moves that this Motion be granted, and Petitioner requests that 

the Tribunal enter an Order: (i) reducing the 2026 assessed and state equalized value from 

$4,219,000 to $2,277,000; (ii) reducing the 2026 taxable value from $4,219,000 to $2,277,000; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled.

Page 3

3 

75658477.1 

Dated: __________________ 

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By: _______________________________________ 

Daniel L. Stanley (P57052) 

222 North Washington Square 

Suite 400 

Lansing, MI 48933-1800 

(517) 377-0714 

dstanley@honigman.com 

/s/ Daniel L. Stanley

May 21, 2026

Page 4

75658477.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MEIJER, INC., 

Petitioner, 

v. 

FREMONT, 

Respondent. 

/

MTT Docket No. 25-002274 

Proof of Service

Lisa Joseph affirms that on _______________ she served a copy of Petitioner's Motion to 

Amend Petition to Contest 2026 Assessed and Taxable Values and this Proof of Service in 

connection with the above-entitled cause upon the following: 

Mark C. Miller 

mark@murphycarismiller.com

Laura M. Hallahan 

Seth A. O’Louhglin 

Kelsea M. Melcher 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

via electronic mail. 

Dated: _____________________ 

__________________________________________

Lisa Joseph 

May 21, 2026

May 21, 2026

/s/ Lisa Joseph

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1 of 1

Docket #: 25-002274

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Joint Motion for Abeyance.pdfRead complete document text →
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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

Meijer, Inc., 

 

 

 

Petitioner, 

 

v 

 

City of Fremont, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002274 

 

 

 

_____________________________________________________________________________/ 

 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

MARK C. MILLER (P68609) 

MURPHY CARIS & MILLER, P.C. 

Attorney for Respondent 

20 E. Main Street 

Fremont, MI 49412 

(231) 924-2226 

 

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 

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-003106 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of the big box store 

commonly known as Meijer – Parcel No. 62-13-33-400-024 - located in Newaygo County.

Page 2

2

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-003106 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure. 

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-003106) has not yet been resolved. A Prehearing Conference is scheduled for 

January 16-30, 2026, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

003106 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

003106 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy.

Page 3

3

8. 

As evidenced above, there is good cause for granting this Motion to hold the above 

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

003106. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-003106. 

 

Respectfully submitted, 

HONIGMAN LLP 

 

/s/ Daniel L. Stanley___________________ 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

 

 

Dated: September 18, 2025 

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 

(248) 731-3089 

 

Dated: September 18, 2025

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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 

Meijer Inc, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-002274 

 

City of Fremont, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

ORDER GRANTING JOINT MOTION TO HOLD CASE IN ABEYANCE 

 

On September 18, 2025, the parties jointly filed a motion requesting that the Tribunal 

hold this case in abeyance pending resolution of Docket No. 24-003106, which is 

currently pending before the Tribunal. In the motion, the parties state that resolution of 

the 2024 case, involving the same parties, parcel, and legal issue, shall have a direct 

effect upon this appeal. They state that resolution of that case may result in the efficient 

administration of justice and guide resolution of this case. 

 

The Tribunal has considered the motion and the case file and finds that the parties have 

shown good cause to grant the motion. Placing this case in abeyance pending 

resolution of Docket No. 24-003106 will facilitate the efficient administration of justice, 

as that resolution may have a direct bearing on the outcome of the instant appeal. 

Therefore, 

 

IT IS ORDERED that the joint Motion to Hold Case in Abeyance is GRANTED. 

 

IT IS FURTHER ORDERED that the parties shall notify the Tribunal in writing within 28 

days of the final resolution of Docket No. 24-003106 as to the need for further 

proceedings in this matter. 

 

 

 

Entered: September 23, 2025 

 

 

By _____________________________ 

bw 

 

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

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

Meijer, Inc., 

 

 

 

Petitioner, 

 

v 

 

City of Fremont, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-002274 

 

 

 

_____________________________________________________________________________/ 

 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

MARK C. MILLER (P68609) 

MURPHY CARIS & MILLER, P.C. 

Attorney for Respondent 

20 E. Main Street 

Fremont, MI 49412 

(231) 924-2226 

 

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 

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-003106 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of the big box store 

commonly known as Meijer – Parcel No. 62-13-33-400-024 - located in Newaygo County.

Page 2

2

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-003106 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal is ready to be placed on a Prehearing General 

Call and Order of Procedure. 

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-003106) has not yet been resolved. A Prehearing Conference is scheduled for 

January 16-30, 2026, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

003106 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

003106 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy.

Page 3

3

8. 

As evidenced above, there is good cause for granting this Motion to hold the above 

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

003106. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-003106. 

 

Respectfully submitted, 

HONIGMAN LLP 

 

/s/ Daniel L. Stanley___________________ 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

 

 

Dated: September 18, 2025 

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 

(248) 731-3089 

 

Dated: September 18, 2025

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Page 1

STATE OF MICHIGAN 

RECEIVED 

JUL 15 2075 

MICHIGAN Tax TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MEIJER, INC., 

Petitioner, 

v 

CITY OF FREMONT, 

Respondent. 

Docket No. 25-002274 

Parcel No. 62-13-33-400-024 

MICHAEL B. SHAPIRO (P20282) 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

MARK C. MILLER (P68609) 

MURPHY CARIS & MILLER, P.C. 

Attorney for Respondent 

20 E. Main Street 

Fremont, MI 49412 

(231) 924-2226 

LAURA M. HALLAHAN (P42101) 

SETH A. O'LOUGHLIN (P80257) 

KELSEA A. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

ANSWER TO SEVERED PETITION 

AFFIRMATIVE DEFENSES 

ANSWER 

Respondent, City of Fremont, by and through its Co-Counsel, Hallahan & Associates, P.C., 

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

Page 2

1. 

Respondent admits the allegations in Paragraph 

1 as to parcel number and parcel 

location. Respondent lacks the information and knowledge necessary to respond to the remainder 

of the allegations set forth in Paragraph 

1 and, therefore, 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. 

4. 

Respondent admits that subject property 

is classified as commercial real. With 

respect to the remainder of the allegations set forth 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 

that Petitioner’s claims have merit and denies that Petitioner is entitled to any relief. 

6. 

Respondent acknowledges Petitioner’s belief relative to the value of a loss but 

denies that such loss has occurred. 

7. 

Respondent neither admits nor denies the statement in Paragraph 7 for the reason 

that no assertion is made. In further answer, Petitioner only sets forth a hypothetical condition (i.e., 

“if P.A. 174 of 2006 requires a board of review protest 

. 

. .) but then fails to state whether or not a 

protest was made. 

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

Page 3

principles, and the values and Respondents 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, City of Fremont, 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. 

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: 

July 9, 2025 

(248) 731-3089 

AFFIRMATIVE DEFENSES 

Respondent, City of Fremont, 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. Alki Development Co v Orion Twp, 110 Mich App 764, 767 (1981).

Page 4

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 

Respondents 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 

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

Page 5

13

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Page 1

RECEIVED #/ 

Sy 

JUN 11 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Meijer, Inc., 

Petitioner, 

v. 

MTT Docket No. 25-002274 

{Parcel No(s). 62-13-33-400-024} 

Fremont, 

Respondent. 

/ 

PROOF OF SERVICE 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and 

June 10, 2025 

that on 

, she did serve a copy of Petitioner's Severed Petition, with docket 

in we 

Lisa Joeph 

lL pd 

number, upon the parties named on the attached list.

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

FREMONT 

101 E. MAIN STREET 

FREMONT, MI 49412 

ASSESSOR 

FREMONT 

101 E. MAIN STREET 

FREMONT, MI 49412 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

NEWAYGO COUNTY 

PO BOX 885 

WHITE CLOUD, MI 49349-0885 

DIRECTOR OF EQUALIZATION 

NEWAYGO COUNTY 

PO BOX 885 

WHITE CLOUD, MI 49349-0885 

SECRETARY OF SCHOOL BOARD 

FREMONT PUBLIC SCHOOLS 

5421 S. WARNER AVENUE 

FREMONT, MI 49412 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922

Page 3

VIA ELECTRONIC MAIL 

Mark C. Miller 

mark@murphycarismiller.com 

Laura M. Hallahan 

lhallahan@hallahanlaw.com 

Seth A. O'Loughlin 

soloughlin@hallahanlw.com 

Kelsea M. Melcher 

melcher@hallahanlaw.com 

25-0088

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ET_Notice_of_Docket_Number.2025-06-16_11-52-30.0000.pdfRead complete document text →
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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

Meijer Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002274

City Of Fremont, 

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: June 16, 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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Meijer v Fremont - Petition (25-002274).pdfRead complete document text →
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Page 1

25-0088 

60800748.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Meijer, Inc., 

Petitioner, 

v. 

MTT Docket No. 25-002274 

 

[Parcel No(s). 62-13-33-400-024] 

Fremont, 

Respondent. 

_________________________/ 

Michael B. Shapiro (P20282) 

Honigman LLP 

Daniel L. Stanley (P57052) 

Attorneys for Petitioner 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

 

 

Mark C. Miller (P68609) 

Murphy Caris & Miller, P.C. 

Attorney for Respondent 

20 E. Main Street 

Fremont, MI 49412 

(231) 924-2226 

mark@murphycarismiller.com 

 

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 

lhallahan@hallahanlaw.colm 

soloughlin@hallahanlaw.com 

kmelcher@hallahanlaw.com 

SEVERED PETITION 

Meijer, Inc. (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1. 

Petitioner's principal office address is 2929 Walker Ave., NW, Grand Rapids, MI 

49544-9428. Petitioner is a party in interest with respect to property taxes on tax parcel no(s). 62-

Page 2

2 

60800748.1 

13-33-400-024 ("Petitioner's Property"), at 7373 W. 48th St. located in Newaygo County, 

Michigan. If this petition includes more than one (1) real property tax parcel, the tax parcels are 

contiguous. 

2. 

Respondent, Fremont, assesses and collects property taxes on Petitioner's Property. 

3. 

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

$4,441,300 and assessed Petitioner's Property at $4,441,300, 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 Real. Petitioner's Property is 

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

was originally designed to be used for Retail purposes. 

5. 

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

value and (d) 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. 

If P.A. 174 of 2006 requires a board of review protest for Petitioner’s Property, a 

board of review protest was filed in March, 2025. 

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 

and operate as a fraud upon the taxpayer 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;

Page 3

3 

60800748.1 

(b) 

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

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

applicable statutes; 

(c) 

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

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

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

principles; and, 

(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 reducing the 2025 

taxable value of Petitioner's Property from $4,441,300 to $2,277,000, and reducing the 2025 

assessed and state equalized value of Petitioner's Property from $4,441,300 to $2,277,000, and 

requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest 

and costs.

Page 4

4 

60800748.1 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dated: ____________________ 

 

Respectfully submitted, 

 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

 

By: _______________________________________ 

 

Michael B. Shapiro (P20282) 

 

Daniel L. Stanley (P57052) 

39400 Woodward Avenue 

Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7622 

mshapiro@honigman.com 

dstanley@honigman.com 

 

 

/s/ Michael B. Shapiro

June 9, 2025

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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 

Meijer Inc, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 24-003106 

 

 

 

 

 

 

 

 & 25-002274 

 

City of Fremont, 

 

Presiding Judge 

Respondent. 

 

Jason C. Grinnell 

 

ORDER DENYING RESPONDENT’S MOTION FOR IMMEDIATE CONSIDERATION 

 

ORDER PARTIALLY GRANTING RESPONDENT’S MOTION TO EXTEND 

 

ORDER REMOVING CASE FROM OCTOBER 16 – 31, 2025 PREHEARING 

GENERAL CALL 

 

ORDER PLACING CASE ON JANUARY 16-30, 2026 PREHEARING GENERAL CALL 

 

ORDER GRANTING PETITIONER’S MOTION TO AMEND 

 

ORDER SEVERING 2025 TAX YEAR AND ASSIGNING IT TO 

DOCKET NUMBER 25-002274 

 

Pending before the Tribunal are Respondent’s Motion for Immediate Consideration of its 

Motion to Extend and Petitioner’s Motion to Amend to Include Tax Year 2025. 

 

On May 9, 2025, Respondent filed a motion requesting the Tribunal extend the June 20, 

2025 valuation disclosure and prehearing statement deadline. Respondent seeks a 

120-day extension due to its appraiser’s unprecedented work schedule. On May 16, 

2025, Petitioner filed a response opposing Respondent’s Motion to Extend contending 

Respondent’s motion does not demonstrate good cause for an extension and is not 

supported with an affidavit from Respondent’s unnamed appraiser. Petitioner also 

opposes Respondent’s request for immediate consideration for not complying with TTR 

231. The Tribunal finds that this is Respondent’s first request for an extension and 

good cause to grant a 90-day extension. Respondent’s Motion for Immediate 

Consideration is denied for failure to comply with TTR 231. 

 

On May 13, 2025, Petitioner filed a motion requesting the Tribunal permit it to amend its 

petition filed in this case to include tax year 2025. On June 3, 2025, Respondent filed a 

response opposing Petitioner’s Motion to Amend or alternatively, that the Tribunal sever 

the 2025 tax year to proceed independently as valuation disclosures are due on June 

20, 2025.

Page 2

MTT Docket No. 24-003106 & 25-002274 

Page 2 of 3 

 

The Tribunal has considered the motion and the response and the case file and finds 

that Petitioner timely filed its Motion to Amend, included the necessary information and 

filing fee, and otherwise met all requirements set forth in MCL 205.737 and MCL 

205.735a. Due to the stage in which this case is at, however, and in the interest of 

judicial efficiency, the 2025 tax year will be severed from this case and assigned to a 

new docket number. 

 

Therefore, 

 

IT IS ORDERED that Respondent’s Motion for Immediate Consideration is DENIED. 

 

IT IS FURTHER ORDERED that Respondent’s Motion to Extend is PARTIALLY 

GRANTED. 

 

IT IS FURTHER ORDERED that this case is REMOVED from the October 16 - 31, 2025 

Prehearing General Call. 

 

IT IS FURTHER ORDERED that this case is PLACED on the January 16 - 30, 2026 

Prehearing General Call. 

 

IT IS FURTHER ORDERED that the parties must file and exchange their valuation 

disclosures by September 19, 2025. Valuation disclosures will not be admitted into 

evidence unless disclosed and furnished in accordance with this Order (even though 

admissible) except upon a finding of good cause by the Tribunal. 

 

IT IS FURTHER ORDERED that the parties must file and exchange their prehearing 

statements by September 19, 2025. Witnesses will not be allowed to testify unless 

disclosed in the Prehearing Statement and the Prehearing Statement is furnished in 

accordance with this Order except upon a finding of good cause by the Tribunal. 

Failure to file the Prehearing Statement will result in holding a party or parties in default, 

as provided by TTR 237. 

 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

September 19, 2025, which means all discovery has been requested, all motions to 

compel have been filed and resolved, and all requested or ordered discovery has been 

exchanged by that date. Discovery relative to the valuation disclosure prepared for 

purposes of litigating this case or the valuation expert that prepared that valuation 

disclosure is not permitted during “Pre-Valuation Disclosure” discovery. 

 

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

January 16, 2026, which means all discovery has been requested, all motions to compel 

have been filed and resolved, and all requested or ordered discovery has been 

exchanged by that date. “Post-Valuation Disclosure” discovery is limited to the 

opposing party’s valuation disclosure, the opposing party’s valuation expert, and the 

witnesses identified in the opposing party’s prehearing statement.

Page 3

MTT Docket No. 24-003106 & 25-002274 

Page 3 of 3 

 

IT IS FURTHER ORDERED that a case listed on this call that is not scheduled for

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