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 full set of factors used for discovery sanctions. Although the Court rejected the Court of Appeals’ required-factor approach, it concluded that the circuit court abused its discretion because plaintiff acted diligently, the discovery period remained open, and the court inadequately assessed prejudice. The resulting summary disposition was premature because it rested on the erroneous denial of plaintiff’s motion to substitute an expert.