West Case Update

Anti-Discrimination Statutes Protect Natural Persons, Not Entities Such as Corporations

Description Michigan appeals court held that the state law against discrimination applied only to persons, not juridical entities such as corporations. Hence, a corporation alleged to have suffered discrimination due to the religion and origins of the owner, has no grounds for suit.

Topic Business Organization

Key Words Discrimination; Corporations

C A S E S U M M A R Y

Facts
Jamal Safiedine, of Arabic origin, manages a gas station in Ferndale, Michigan. The station is owned by a corporation owned by Safiedine and members of his family. He sued the City of Ferndale for violating the Michigan Civil Rights Act (CRA). He claimed that Ferndale police officers made discriminatory comments to Safiedine and dissuaded customers from patronizing his gas station. He contended that the discrimination was based on is Arabic national origin and his Islamic religion. The trial court dismissed the suit; Safiedine appealed.

Decision
Affirmed. The CRA’s antidiscrimination provisions protect only natural persons, not juridical persons such as corporations. Since the discrimination was alleged to have been directed at the gas station, which is owned by a corporation, there is no basis for suit. The statute clearly refers to “persons” and issues regarding hiring, firing, compensation, and other matters of employment, and also concerns discrimination in public accommodations, such as in restaurants and motels. The statute does not apply to claims of discrimination directed at a corporation or other juridical entities.

Citation Safiedine v. City of Ferndale, ---N.W.2d---, 278 Mich.App. 476 (Ct. App., Mich., 2008)

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Anti-Discrimination Statutes Protect Natural Persons, Not Entities Such as Corporations
Description	Michigan appeals court held that the state law against discrimination applied only to persons, not juridical entities such as corporations. Hence, a corporation alleged to have suffered discrimination due to the religion and origins of the owner, has no grounds for suit.
Topic	Business Organization
Key Words	Discrimination; Corporations
C A S E S U M M A R Y
Facts	Jamal Safiedine, of Arabic origin, manages a gas station in Ferndale, Michigan. The station is owned by a corporation owned by Safiedine and members of his family. He sued the City of Ferndale for violating the Michigan Civil Rights Act (CRA). He claimed that Ferndale police officers made discriminatory comments to Safiedine and dissuaded customers from patronizing his gas station. He contended that the discrimination was based on is Arabic national origin and his Islamic religion. The trial court dismissed the suit; Safiedine appealed.
Decision	Affirmed. The CRA’s antidiscrimination provisions protect only natural persons, not juridical persons such as corporations. Since the discrimination was alleged to have been directed at the gas station, which is owned by a corporation, there is no basis for suit. The statute clearly refers to “persons” and issues regarding hiring, firing, compensation, and other matters of employment, and also concerns discrimination in public accommodations, such as in restaurants and motels. The statute does not apply to claims of discrimination directed at a corporation or other juridical entities.
Citation	Safiedine v. City of Ferndale, ---N.W.2d---, 278 Mich.App. 476 (Ct. App., Mich., 2008)