Smith v. Beaumont Health

Summary

The Michigan Supreme Court held that a motion to amend a witness list is governed by the good-cause standard in MCR 2.401(I)(2), not by the multifactor framework used for discovery sanctions. Applying that standard, the court concluded that the circuit court abused its discretion because plaintiff acted diligently in attempting to secure and replace her expert and the court inadequately assessed prejudice. The resulting summary disposition was premature because it was based on the erroneous denial of plaintiff's motion to amend.