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 # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 10 | A response to motion was filed. | Not recorded | Not recorded | 06/11/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 9 | Motion to Amend Subsequent Year was received. | PET | Not recorded | 05/21/2026 | $300.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 8 | Granted | PET | 6 | 09/23/2025 | Not recorded | Download |
| 7 | Order granting Motion. | Not recorded | 6 | 09/23/2025 | Not recorded | Download |
| 6 | Motion for Abeyance was received. | PET | Not recorded | 09/18/2025 | $50.00 | Download |
| 5 | Answer was received | RESP | Not recorded | 07/10/2025 | Not recorded | Download |
| 4 | Proof of service of petition was received. | PET | Not recorded | 06/11/2025 | Not recorded | Download |
| 3 | Notice of Docket Number ET | Not recorded | Not recorded | 06/16/2025 | Not recorded | Download |
| 2 | A petition has been filed. | PET | Not recorded | 06/09/2025 | Not recorded | Download |
| 1 | Order Severing 2025 Tax Year from 24-003106 | Not recorded | Not recorded | 06/05/2025 | Not recorded | Download |
Documents
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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
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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
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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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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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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:
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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.
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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
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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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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.
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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.
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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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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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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.
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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.
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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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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:
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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
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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).
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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
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13
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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
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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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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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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-
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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.
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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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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.
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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.
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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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