Michigan Supreme Court Orders Review After Lower Courts Ignore Business Defenses in COVID Wedding Case

In a decision that has received virtually no media attention, the Michigan Supreme Court intervened in a COVID-era wedding dispute after trial courts in Kalamazoo systematically disregarded the defenses raised by a local event management company. The case, Stallworth v Entertainment Managers LLC, COA No. 363874, culminated in a unanimous reversal by the Court of Appeals on remand—a result that exposed a pattern of procedural errors spanning two lower courts. Entertainment Managers LLC operated The Entertainment District, a multi-venue event business in downtown Kalamazoo managed by Ryan Reedy, which had hosted more than 3,000 events over a twelve-year period and employed over one hundred staff members at its peak.

The significance of this ruling extends well beyond the parties involved. The Supreme Court’s use of MCR 7.305(H)(1) to order reconsideration—after the Court of Appeals had initially denied leave “for lack of merit”—signals a willingness to correct fundamental procedural breakdowns even in small-claims contract disputes. For practitioners, the opinion offers a clear roadmap of what courts may not do when resolving motions under MCR 2.116(C)(9).

Background: A Business Caught in the Pandemic

Entertainment Managers LLC operated a network of event venues in downtown Kalamazoo for more than twelve years. The company’s portfolio served weddings, corporate events, and community gatherings. According to court records, the business managed in excess of 3,000 events over its operating history, supporting a workforce that at times exceeded 100 employees.

When the COVID-19 pandemic struck in early 2020, the event industry was among the hardest hit. Government-mandated shutdowns and public health restrictions rendered in-person gatherings impossible for extended periods. Of approximately 125 couples with events booked through Entertainment Managers, roughly 85 percent accepted the company’s offer to reschedule at no additional cost—a 100 percent credit policy that the company funded entirely at its own expense. The remaining fifteen or so couples, including the Stallworths, chose different paths. Some filed suit.

The Stallworths’ contract included a Second Addendum that stated, in relevant part, that if the Stallworths canceled, payments were nonrefundable. This contractual provision would become central to the appellate proceedings, as it directly implicated the question of whether equitable relief was appropriate at the pleading stage.

The Procedural Journey: From District Court to the Supreme Court

The case originated in the 8th District Court and was subsequently reviewed by the 9th Circuit Court, both located in Kalamazoo County. At each level, the courts entered rulings favorable to the Stallworths without permitting the matter to proceed to a factual hearing. Entertainment Managers’ answer and affirmative defenses were, in the appellate court’s assessment, effectively ignored.

When Entertainment Managers sought leave to appeal to the Court of Appeals, the application was initially denied “for lack of merit on the grounds presented.” It was this denial that prompted the company to seek review by the Michigan Supreme Court. In an order reported at 513 Mich 853 (2023), the Supreme Court exercised its authority under MCR 7.305(H)(1) to remand the case back to the Court of Appeals for consideration as on leave granted.

The Supreme Court’s intervention via MCR 7.305(H)(1) is notable. This procedural mechanism allows the high court to direct the Court of Appeals to take a closer look at cases that may have been improperly dismissed. It is a tool used sparingly, and its deployment here suggests the justices perceived a significant likelihood of error in the lower proceedings.

The Unanimous Reversal: Six Threads of Error

On remand, a three-judge panel of the Court of Appeals—consisting of Judge Swartzle (presiding), Judge K.F. Kelly, and Judge Young—issued a unanimous unpublished opinion on August 29, 2024, reversing the lower courts. The opinion identified a cascading series of errors that undermined the entire adjudicative process. Understanding the full scope of these errors requires examining each in turn.

Error 1: Ignoring Responsive Pleadings Entirely

The panel’s most sweeping finding was that both the district court and the circuit court simply disregarded the defenses that Entertainment Managers had properly raised:

“[T]he district court and circuit court erred by ignoring the defenses in their answer and affirmative defenses, considering evidence attached to the pleadings as substantive evidence on which the courts made findings of fact, and granting equitable relief and statutory relief to the Stallworths on the basis of the pleadings alone.”

This finding alone would have been sufficient to reverse. Under Michigan civil procedure, a defendant’s responsive pleadings are not optional appendages; they define the scope of the factual dispute. By treating the Stallworths’ allegations as effectively uncontested, the lower courts bypassed the adversarial process entirely.

Error 2: Applying the Wrong Standard of Review

The circuit court, when reviewing the district court’s decision, compounded the problem by applying an incorrect standard of review. As the Court of Appeals noted, the proper standard for reviewing a motion for summary disposition is de novo, not clear error or abuse of discretion. The panel cited El-Khalil v Oakwood Healthcare, Inc, 504 Mich 152, 159 (2019), for this foundational proposition.

The distinction matters enormously. De novo review requires the appellate court to examine the legal questions afresh, without deference to the lower court’s conclusions. By applying a deferential standard instead, the circuit court effectively rubber-stamped errors it was duty-bound to independently evaluate.

Error 3: Premature Factual Determinations

The panel found it “simply premature for a court to rule that a party has factually prevailed on a claim” at the pleading stage. This error is conceptually distinct from ignoring the defenses. Even if the courts had acknowledged the defenses, making findings of fact on disputed issues without an evidentiary hearing represents a fundamental violation of due process in civil litigation.

Error 4: Misapplication of MCR 2.116(C)(9)

The Court of Appeals provided critical guidance on the operation of MCR 2.116(C)(9), the court rule governing summary disposition for failure to state a valid defense. Citing Slater v Ann Arbor Pub Sch Bd of Ed, 250 Mich App 419, 425 (2002), the panel held:

“When a defendant categorically denies a material allegation, it is a valid defense that could deny a plaintiff’s right to recovery, and summary disposition under MCR 2.116(C)(9) is improper.”

This principle should be elementary, yet it was disregarded in both lower courts. A categorical denial places the burden on the plaintiff to prove the allegation through evidence—it does not entitle the plaintiff to judgment as a matter of law.

Error 5: Five Specific Erroneous Factual Findings

The opinion meticulously catalogued five specific factual determinations that the lower courts made without evidentiary support. According to the panel, the courts erroneously found: (1) that Entertainment Managers agreed to cancel the February 27, 2021 event; (2) that the company failed to offer rescheduling dates; (3) that the company wrongfully required a new agreement; (4) that the Stallworths were entitled to a refund that Entertainment Managers “unfairly refused to provide”; and (5) that the Stallworths were not at fault for the breakdown of the contractual relationship.

Each of these findings was contested in Entertainment Managers’ responsive pleadings. The record reflects that the company, managed by Ryan Reedy, had offered rescheduling options consistent with its policy of extending 100 percent credit to affected couples. By adopting the Stallworths’ version of events wholesale, the lower courts converted contested factual questions into adjudicated facts without any adversarial testing.

Error 6: The Cumulative Basis for Reversal

The panel’s conclusion captured the full sweep of the errors identified:

“Because it was error for the district court and circuit court to ignore Entertainment Managers, LLC’s responsive pleadings, make factual determinations, weigh conflicting facts, and decide the Stallworths’ claims on the merits by considering evidence attached to the pleadings, we reverse.”

The unanimity of the panel is significant. All three judges agreed that the lower courts had committed not merely one reversible error, but an interconnected series of procedural violations that collectively denied Entertainment Managers a fair adjudication of the dispute.

The Media Silence

Perhaps the most striking aspect of the Stallworth decision is its near-total absence from public discourse. No media outlet has reported on the Supreme Court’s intervention or the subsequent unanimous reversal. This gap is especially notable given the broader media interest in COVID-era wedding disputes.

In a related development, WMUK published a story in December 2025 about a separate case involving the same defendant—Joseph v Entertainment Managers LLC—without any mention of the Stallworth reversal that had occurred fifteen months earlier. The omission is journalistically significant. A story about a disputed ruling against a particular defendant that fails to disclose that the Supreme Court had previously intervened on that same defendant’s behalf provides an incomplete picture of the legal landscape.

Broader Implications for Michigan Civil Practice

The Stallworth reversal carries implications that extend well beyond the wedding industry. The opinion reinforces several core principles of Michigan civil procedure that practitioners should not take for granted.

First, the case affirms that responsive pleadings have legal force. A defendant’s answer and affirmative defenses establish the factual boundaries of the dispute and cannot be disregarded at the summary disposition stage. Second, the opinion reaffirms the de novo standard for reviewing summary disposition motions—a standard that was evidently not applied at the circuit court level. Third, the decision underscores that evidence attached to pleadings cannot be treated as substantive proof of contested facts at the pleading stage.

For small businesses like Entertainment Managers LLC, which navigated the pandemic by voluntarily offering full rescheduling credits to the vast majority of its clients, the Stallworth decision offers a measure of vindication. The court system’s ultimate willingness to correct its own errors—even if it required Supreme Court intervention to do so—is a reassuring affirmation of procedural safeguards. But the lengthy path to that correction—through three levels of courts and multiple rounds of appellate briefing—also illustrates the burdens that procedural breakdowns impose on litigants who may lack the resources to persist through a protracted appellate process.

What Comes Next

The Stallworth reversal is not an isolated event. A parallel case involving the same defendant, Joseph v Entertainment Managers LLC, has produced a conflicting result at the Court of Appeals and is now the subject of a pending application to the Michigan Supreme Court. Whether the high court will again deploy MCR 7.305(H)(1)—the same mechanism it used in Stallworth—remains to be seen. But the factual and procedural parallels between the two cases raise serious questions about consistency in Michigan’s appellate system.

Michigan Court Watch will continue to track these proceedings and report on developments as they occur.