Hinkle v. Wayne County Clerk

This appeal arises from postjudgment proceedings in a dispute over a partial refund owed by a hospital that was overpaid for the care of plaintiffs decedent, Marilyn J. Hinkle-Calcutt.

We hold that MCR 2.614(A)(1), commonly described as the automatic stay provision, does not apply to voluntary payments in satisfaction of a judgment. Therefore, we reverse the judgment of the Court of Appeals to the extent that it holds to the contrary.

i

While the plaintiffs decedent was a patient at Harper-Grace Hospital, two insurance companies made duplicate payments for her care. Harper-Grace was prepared to…