2026-09-12 · Michigan · Courts

What happened. In a published decision issued 13 January 2025, the Michigan Court of Appeals affirmed a slander-of-title judgment against co-owners who recorded a lis pendens asserting a statutory reversion and left it on title after their underlying claims were dismissed. Shenandoah Ridge Condominium Association v Bodary, No. 364972, Livingston Circuit Court — panel of Yates (writing), Patel and Murray.¹

Because it is published, it binds Michigan trial courts.

The two holdings

First, standing. In a site-condominium reversion fight, individual co-owners lacked standing to bring the quiet-title and reversion claim. Only the condominium association had it.

Second, the lis pendens. Recording a notice asserting reversion under MCL 559.167(3) and then leaving it on title for months after the underlying claims were dismissed supported a slander-of-title claim. The special damages awarded were $41,009 and $9,903 — for a lost refinancing opportunity, attorney fees, and reduced vendibility of the property.

Why this is the counterweight to the rest of the reversion line

Michigan's recent appellate output on unbuilt condominium units runs heavily in favour of associations: units that were never designated “must be built” disappear by operation of law, roads and utilities do not make them “developed,” and a letter from a developer's lawyer changes nothing.

Shenandoah Ridge is the case that says: being right about the law does not protect you from how you assert it.

1. Shenandoah Ridge Condominium Ass'n v Bodary, Mich Ct App No. 364972 (13 Jan 2025, published) ↩
2. Shenandoah Ridge v Bodary — listed among Michigan Court of Appeals published opinions, 2025 ↩