Tyler v. Findling, 508 Mich. 364, 972 N.W.2d 833 (2021), reh'g denied, 508 Mich. 940, 964 N.W.2d 41 (Mem)(Sept. 22, 2021)

Authors

James Coben, Mitchell Hamline School of LawFollow

Subject Area

Confidentiality

Document Type

Video

Publication Date

11-22-2022

Comments

Playtime: 1:18 minutes

Deeming conversation between a court-appointed receiver and plaintiff’s counsel to be protected mediation communications when made within the mediator's designated “plaintiff's room” while parties to the mediation were waiting for the mediation session to start.

Quote from the Court: "There is no requirement in MCR 2.412 that a “mediation communication” be uttered by any particular party or participant. Rather, the rule simply explains to whom confidential mediation communications can be disclosed. All mediation communications made by participants are afforded confidentiality protections." 508 Mich. at 373, 972 N.W.2d at 837.

Recommended Citation

Coben, James, "Tyler v. Findling, 508 Mich. 364, 972 N.W.2d 833 (2021), reh'g denied, 508 Mich. 940, 964 N.W.2d 41 (Mem)(Sept. 22, 2021)" (2022). Mediation Case Law Teaching Videos. 43.
https://open.mitchellhamline.edu/dri_mclvideo/43