Dimmitt & Owens Financial, Inc v. Deloitte & Touche (Isc), LLC

In this accounting malpractice action, we consider where an “original injury” occurs for purposes of determining venue under MCL 600.1629(l)(a) and (b). We conclude that the location of the original injury is where the first actual injury occurs that results from an act or omission of another, not where a plaintiff contends that it first relied on the act or omission that caused the injury. Reliance creates only a potential injury, which is insufficient to state a negligence cause of action and, consequently, cannot constitute the original injury necessary to establish venue. Accordingly, we…