How does a Michigan landlord lawfully end a tenancy, and when may a tenant leave early?

Three Michigan rules on this page reach only leases signed, renewed, or renegotiated after a stated date, so the date on the lease decides whether the tenant has the right at all. The release from rent for a tenant in danger from domestic violence, sexual assault, or stalking applies only to leases entered into, renewed, or renegotiated after October 5, 2010. The right of a long-staying tenant to leave for subsidized senior housing or because of an inability to live independently applies only to leases entered into, renewed, or renegotiated after June 15, 1995. And the Truth in Renting Act, which is what voids a lease clause releasing the duty to re-let, conditions an acceleration clause, and blocks a lease from cutting down notice and possession rights, does not apply to a rental agreement entered into before July 1, 1979. The notice periods for ending a periodic tenancy apply to everyone regardless of vintage.

The reader looks at the date on the lease as signed, and at any renewal or renegotiation since, because renewing or renegotiating brings an older tenancy inside these rules. A tenant on an original lease from before one of the dates who has simply stayed on without renewing is outside the corresponding right. Nothing turns on where in the state the property is or on the type of building.

The switch changes: landlord's duty to re-let after an early move-out; early-termination fees; and when a tenant may end the lease early.

Landlord: one calendar month. Tenant: one calendar month.

Michigan sets a period rather than a day count. The statute says one month's notice, which is a calendar month and not 30 days, so on a tenancy running from the first of the month a notice given in a 31-day month buys the tenant 31 days. Where rent is payable at intervals of less than three months, the notice period is instead equal to the interval between rent payments, which makes a week-to-week tenancy one week and leaves no 30-day floor underneath it. The date the notice names does not have to fall at the end of a rental period. The statute says in terms that a notice is not void because it names a termination day that does not match the start or end of a rental period, and that such a notice ends the tenancy at the end of a period equal in length to the interval between rent payments. So a mis-dated notice is cured by the statute rather than thrown out, which is the opposite of the rule in most states.

The termination date may fall on any day.

Tiers: Three tracks, all set by the length of the tenancy's own period. A tenancy at will or by sufferance, which includes the ordinary month-to-month tenancy, takes one month's notice. Where rent is payable at intervals shorter than three months, the notice equals that interval, so a week-to-week tenancy takes one week. A tenancy from year to year is different in shape rather than in length: notice may be given at any time, and it ends the lease one year from the date the notice is served. No track turns on how long the tenant has lived there, on the building, on the size of the landlord's holdings, or on where in the state the property is.

A lease may not change the period. The termination statute itself says nothing about waiver; the bar comes from the Truth in Renting Act. A rental agreement may not include a provision waiving or altering a party's right to any notice or procedure required by law in a judicial proceeding arising under the agreement, or waiving or altering a party's rights over possession or eviction proceedings, and a provision that does is void. The act's requirements may not be waived. So a lease clause cutting the notice period down is void so far as it alters the possession right, and nothing anywhere in Michigan law expressly lets the parties agree a different period. The act does not reach a rental agreement entered into before July 1, 1979.

A statute requires the landlord's and tenant's periods to be equal, or bars a lease from imposing a longer period on one side.

Source of the period: a termination-notice statute states it.

One section of an 1846 statute carries the whole rule, MCL 554.134. Either party may end an estate at will or by sufferance by giving one month's notice to the other, and where rent is payable at intervals of less than three months the notice period equals the interval between rent payments. Either party may end a tenancy from year to year by a notice to quit given at any time, and that notice ends the lease one year from the day it is served. The periods are the same for landlord and tenant, because the statute says either party in both places. Subsection (1) does not even require the notice to be in writing, and prescribes no form, no content, and no method of delivery. The date the notice names need not line up with a rental period, and a notice that names a mis-aligned date is not void: it ends the tenancy at the end of one further period equal to the rent interval. Two shorter notices sit in the same section but belong to the eviction page rather than here, because both require a reason: a written 7-day notice to quit for unpaid rent, and a 24-hour notice to quit after a lease is terminated under a controlled-substance clause and a formal police report has been filed.

Only for a defined subset of tenancies. Two routes bring a tenancy inside Michigan's good-cause requirement, and they work differently.

How a tenancy comes inside the rule: more than one route brings a tenancy inside the rule.

Who is covered: The first is statutory and direct: housing in a project or facilities operated by a city, village, township, or other unit of local government under the Housing Facilities Act may not have a tenancy or a contract right to occupy terminated by the management or the local housing commission except for just cause. The second is contractual and comes in as a condition of state assistance: the State Housing Development Authority may not provide assistance for multifamily housing unless the owner or manager agrees in writing not to evict a tenant without just cause as the same section defines it, so the standard reaches assisted multifamily housing through the owner's own written agreement rather than by a direct command. Everything else, meaning every private and unassisted tenancy in Michigan, needs no reason at all.

Local ordinances: no statute or decision addresses them. No Michigan statute either authorizes or preempts a local just-cause or eviction-control ordinance, and the phrase rent control does not appear anywhere in the compiled laws. There is an express local bar, but it reaches only price: a local governmental unit may not enact, maintain, or enforce an ordinance or resolution having the effect of controlling the amount of rent charged for leasing private residential property, subject to two savings clauses for property in which the local unit has an interest and for voluntary incentive and agreement programs to increase moderate- and low-cost rental supply. That rent posture is carried on the rent-increase page and says nothing about the grounds for ending a tenancy.

No reason is needed to end a private Michigan tenancy: the landlord gives the statutory notice and the tenancy ends. The good-cause requirement reaches locally-operated public housing and, through a required written agreement, state-assisted multifamily housing. For those tenancies the grounds are open-ended rather than a closed list, because the statute says just cause includes but is not limited to failing to comply with the lease or the housing commission's lawful rules, using a unit for an unlawful purpose, and maintaining an unsafe, unsanitary, or unhealthful condition in the unit or the common areas. Each municipal housing commission must adopt published rules setting out just cause for termination so that a tenant is clearly apprised of the precise reasons. Two provisions enforce it: a tenant of locally-operated housing is not treated as holding over unless the tenancy was terminated for just cause, and a judgment for possession may not be entered where the alleged termination was of a tenancy in such housing and was made without cause. Because the grounds list is open-ended there are no no-fault grounds to satisfy and no relocation payment anywhere in Michigan law. Separately, and for every tenancy, a judgment for possession may not be entered on a retaliatory termination, with a presumption that runs in the tenant's favor where the protected act happened within 90 days before the case was started; that bar is covered on the habitability page.

The term ends on its date; no statute requires notice from either side.

After the term, nothing converts: a holdover creates no new tenancy. No Michigan statute turns a holdover into a new term or a new periodic tenancy, and none makes the landlord's acceptance of rent do it. What the statute does instead is treat the person who stays on as holding an estate at will or by sufferance, which the landlord then ends with the ordinary one month's notice, or the rent interval where rent is payable at intervals of less than three months. Whether Michigan's court decisions imply a periodic tenancy when a landlord accepts rent after a term expires is a question of common law with no statutory text behind it, and this page does not answer it.

A fixed-term lease ends on its date. Michigan requires no notice of non-renewal from either side and no notice before the term runs out: the expiry of the term is itself a ground for the landlord to bring summary proceedings for possession, standing on its own beside the two other holdover grounds. There is no statute requiring a reminder before an automatic-renewal clause takes effect in a residential lease; the automatic-renewal reminder statutes Michigan has are about municipal contracts, insurance, school districts, and conservation easements. A tenant who stays on after the term holds an estate at will or by sufferance and can be given the ordinary notice, but nothing converts the tenancy into a new term by operation of law.

A tenant who stays on holds an estate at will or by sufferance, which is what the termination section is written to end. The landlord has three separate footings for summary proceedings against a person holding over: after the lease was terminated under a power in the lease or implied by law, after the term for which the premises were let has run out, and after the person's estate was ended by a notice to quit under the termination statute. Only the third of those needs a notice to quit first; expiry of the term needs none.

Damages: No statutory enhancement: the landlord recovers ordinary rent or use and occupancy.

Michigan has no holdover damages provision at all: no double rent, no treble damages, no holdover rent set by statute, and no liquidated measure. A landlord who obtains a judgment for possession is entitled to a separate civil action against the tenant for damages, running from the time of the forcible entry or detainer, the trespass, or the notice of forfeiture, notice to quit, or demand for possession, as the case may be. That is an ordinary damages claim in which the landlord proves the loss. Michigan's multiplied damages run the other way: a tenant unlawfully put out of possession may recover three times the actual damages or $200, whichever is greater, together with possession.

Yes: an appellate decision imposes the duty; no statute does.

When it attaches: The duty attaches when the tenant wrongfully leaves the property, and it does not wait on the landlord electing anything. A tenant's decision to leave does not by itself release the tenant: releasing the tenant takes the agreement of both parties, so the landlord who does not agree keeps the rent claim and takes on the duty to make reasonable efforts to reduce it.

Burden of proof: on the tenant.

The standard: The landlord must make every reasonable effort within the landlord's power to reduce the loss. Asking a higher rent when re-letting is not by itself a failure, though it can be evidence that the landlord did not act reasonably, and anything the landlord actually gains from a re-letting reduces what the departing tenant owes. The burden of proof is on the tenant: a landlord suing for the rent does not have to prove having tried, and a tenant who says the landlord did not try must establish it. That allocation comes from the Supreme Court's general contract rule rather than from anything specific to leases.

A lease clause accelerating all remaining rent is enforceable only with an offset for re-letting or another limit.

The lease may not waive the duty.

Michigan has no mitigation statute, and the duty comes from the Court of Appeals. Where a tenant wrongfully leaves, the landlord has a duty to use reasonable efforts to reduce the damages the breach causes, and a tenant's departure does not release the tenant unless the landlord agrees to it. The burden of proving that the landlord did not use every reasonable effort is on the tenant, following the Supreme Court's general contract rule from 1941 and its restatement in 1962. A 1957 Supreme Court decision is often cited for the opposite proposition, that a Michigan landlord may sit idle and sue for the whole term, but the Court said in terms that it did not need to grapple with the question and did not decide either the duty or the burden; the Court of Appeals then settled the point. Every published Michigan decision on the subject arose from a commercial lease, so the residential reach rests on the general contract rule and on the Truth in Renting Act, which assumes the duty exists in residential agreements: a rental agreement may not include a provision releasing a party from a duty to mitigate damages, and such a provision is void. That act also conditions acceleration rather than banning it. A clause accelerating the rent on a tenant's breach is permitted only if it also states that the tenant may not be liable for the whole accelerated amount because of the landlord's obligation to minimize damages, and that either party may have a court decide the actual amount owed. The act's requirements may not be waived, and it does not reach agreements entered into before July 1, 1979.

No statute addresses a fee a landlord may charge for ending a lease early; the general damages rules govern.

No Michigan statute authorizes, caps, or bars a fee for ending a residential lease early, and none caps the damages after an early departure. The general damages rules govern, which in Michigan means the landlord must use reasonable efforts to re-let, though the tenant carries the burden of showing a failure to do so. What Michigan regulates instead is the wording of the lease, through the Truth in Renting Act, and four of its bans matter here: a clause releasing a party from the duty to mitigate damages is void; an acceleration clause is allowed only if it states that the tenant may not be liable for the whole accelerated amount because of the landlord's obligation to minimize damages and that either party may have a court fix the actual sum; a clause making a party liable for the other's legal costs or attorney fees beyond what a statute specifically permits is void; and a lease may not create a security interest in the tenant's own property to secure the rent. A violating clause is void and the act's requirements may not be waived. The state's administrative rules were read at the rule-set level: the only tenancy-adjacent rule sets in the whole Michigan Administrative Code are the housing development authority's general rules, manufactured housing, and mobile home and seasonal motor home parks, and none of them caps a residential early-termination fee.

Early-exit rights by ground: domestic violence and related grounds, a release from rent only; military service beyond the federal act, the state adds nothing to the federal Servicemembers Civil Relief Act; death of the tenant, no statute; and other statutory grounds.

Domestic violence and related grounds: a release from rent without a termination mechanism.

Who qualifies: The tenant, or the tenant's child, where the tenant has a reasonable apprehension of present danger from domestic violence, sexual assault, or stalking arising while that person is a tenant. Child means a minor child living with the tenant or an adult child who is a legally incapacitated individual. The three covered kinds of violence each take their meaning from another Michigan statute. Human trafficking is not a covered ground; no Michigan tenancy statute mentions it. The test is a present danger rather than a past incident, which is why there is no look-back period.

Documentation: The tenant sends written notice of the intent to seek a release, by certified mail, with one of five kinds of documentation. Any one is enough. A valid personal protection order, a valid foreign protection order, or a court order removing an abusive person from the home, in each case still in effect on the day the notice is sent. A valid probation, conditional release, or parole order still in effect that imposes no-contact conditions. A written police report that led to charges being filed no more than 14 days before the notice is sent. The same kind of police report where the charges were filed more than 14 days before, together with a showing of a verifiable threat of present danger, which the fifth route satisfies on its own. Or a report from a qualified third party on the form the statute prints, sworn under penalty of perjury and carrying the provider's license number or organizational tax identification number. A qualified third party is a sexual assault or domestic violence counselor, a licensed health professional, a mental health professional, or a member of the clergy affiliated with a tax-exempt religious institution listed in a telephone directory.

Window: The statute states no window. What matters is a reasonable apprehension of present danger at the time the tenant asks for the release, not how recently something happened. The only date rule anywhere in the section is the split between a police report where charges were filed within the past 14 days, which stands on its own, and one where they were filed earlier, which needs an additional showing of a verifiable threat of present danger.

Notice: There is no notice period, because this is not a right to end the tenancy on a future date. The tenant sends the written notice and documentation by certified mail, and the release from the rent obligation lands no later than the first day of the second month that rent is due after the notice is given. That is an outer limit on how long the obligation can run, not a period the tenant must sit through, and it is not a termination of the lease.

Rent owed: Rent keeps running until the release takes effect, and the release does not take effect before the tenant has actually left. It does not reach prepaid amounts, including a prepayment of the first and last months' rent, so those stay with the landlord. The landlord's ordinary right to withhold from the security deposit is untouched. The lease itself is not terminated by any of this; what ends is the tenant's obligation to pay rent going forward.

Cost to the tenant: The statute bars no fee and no penalty. The tenant loses prepaid amounts, including prepaid first and last months' rent, and remains exposed on the security deposit under the ordinary rules.

Other tenants on the lease: the lease continues for the other tenants. Where a rental agreement makes several tenants liable for the rent and one of them is released under this section, every other tenant who is a party to the agreement stays subject to it. The statute says so in terms, so a co-tenant's release does not reduce what the others owe.

Locks: Lock changes are not addressed.

Later screening: no statutory protection.

The landlord must keep the victim's documentation or status confidential.

The landlord's side: The landlord may insist on the certified-mail submittal and on one of the five listed forms of documentation. Nothing in the act prejudices the landlord's right to pursue the remedies it allows against other parties, and the other tenants on the lease stay bound. Against that, the landlord must keep the tenant's forwarding address information in confidence, revealing it to others only as reasonably necessary for the landlord's regular and ordinary business purpose, and must not intentionally reveal that information or the documentation to the person the tenant has named as the source of the danger. No figure for damages attaches to a breach of that duty.

Lease disclosure: Michigan requires the tenant to be told about the right, with two ways of doing it. The rental agreement may carry the statutory sentence saying that a tenant with a reasonable apprehension of present danger to the tenant or the tenant's child from domestic violence, sexual assault, or stalking may have special statutory rights to seek a release of the rental obligation, with the citation. If the agreement does not carry it, the landlord must post written notice where a reasonable person would see it in the landlord's property management office, or deliver written notice to the tenant when the lease is signed, and the wording must be identical to the statute's.

Michigan does not let a survivor end the lease. What it gives is a release from the obligation to pay rent, which is a narrower thing and is worth understanding precisely. A tenant with a reasonable apprehension of present danger to the tenant or the tenant's child from domestic violence, sexual assault, or stalking, arising while that person is a tenant, is released from the rental payment obligation after sending the landlord written notice of the intent to seek a release, by certified mail, with one of five listed forms of documentation. The release lands no later than the first day of the second month that rent is due after the notice, and it does not take effect before the tenant has actually left. The lease itself is not terminated, prepaid amounts including first and last months' rent are not returned, the deposit rules are untouched, and every other tenant on the agreement stays liable. There is no lock-change right, no bar on the termination showing up in a screening report, and no fee or penalty bar. The landlord must keep the tenant's forwarding address and documentation confidential, and must not reveal them to the person named as the source of the danger. The right reaches only leases entered into, renewed, or renegotiated after October 5, 2010.

Military service: The state adds nothing to the federal Servicemembers Civil Relief Act.

Michigan adds no lease-termination right to the federal Servicemembers Civil Relief Act, which is the only route for a Michigan service member who needs out of a lease on orders. The Michigan Military Act does give a service member on state active service for more than seven days, ordered by the governor in support of civilian authority or in time of war or emergency, a set of protections a landlord will meet in practice: the member is privileged from arrest and imprisonment during the service and for six months afterwards, separate property is exempt from levy, seizure, or attachment for debts contracted before or during the service, suits in Michigan courts pending when the member enters service or started during it stand adjourned until after the service ends, forfeiture of an executory contract may not be enforced against the member during the service or for 90 days afterwards, and the member's household may not be cut off from heat, water, electricity, or gas over unpaid bills during the first 90 days of service. The adjournment reaches a possession case. Whether the bar on enforcing forfeiture of an executory contract reaches forfeiture of a residential lease has not been decided by a Michigan court. None of this ends a lease; it delays and protects.

Death of the tenant: No statute gives a right to end the lease on the tenant's death.

Other grounds: Michigan has one statutory way out beyond the survivor release, and it is aimed at older and disabled tenants. A rental agreement must provide that a tenant who has occupied the unit for more than 13 months may end the lease on 60 days' written notice to the landlord if either of two things happens during the lease term: the tenant becomes eligible to take possession of a subsidized rental unit in senior citizen housing, meaning housing for people aged 62 or older subsidized under any local, state, or federal program, and gives the landlord written proof of that eligibility; or the tenant becomes incapable of living independently, certified by a physician in a notarized statement. It reaches only leases entered into, renewed, or renegotiated after June 15, 1995. One drafting point is worth flagging rather than glossing over: the duty is written as something the rental agreement must provide rather than as a right the statute gives directly, and no Michigan court has decided what happens where the lease leaves the clause out. Michigan has no job-relocation ground, no casualty or destruction ground, and no landlord-harassment termination ground. Ending a lease over conditions, and the statutory covenants of fitness and repair, are covered on the habitability page; a tenant unlawfully put out of possession has a damages and possession remedy rather than a right to end the lease.

No statute treats absence as ending the tenancy; the common law governs.

Michigan has no abandonment statute for tenancies. Nothing deems a tenancy ended because the tenant has gone, there is no notice of belief of abandonment to serve, and there is no window in which the tenant answers one. Abandonment appears in Michigan landlord-tenant law in one place only, and it is a defense rather than a termination: a landlord's actions do not unlawfully interfere with the tenant's possession where the landlord believes in good faith that the tenant has abandoned the premises, has reason to believe after diligent inquiry that the tenant does not intend to return, and current rent is unpaid. All three have to be true together, and the effect is that the landlord is not liable for re-entering, not that the tenancy has ended. The same section carries a separate track after a tenant's death, again a defense and not a termination, which requires all of the following: the landlord told the tenant in writing of the option to name an authorized contact person, current rent is unpaid, the landlord believes in good faith the tenant has been dead for at least 18 days with no surviving tenant, no probate estate has been opened, and, at least 10 days before re-entering, the landlord made a reasonable attempt to reach the contact person and ask them to open an estate within 28 days of the death, placed a notice on the door of the intent to re-enter and dispose of the contents after 10 days, and notified the county or state public administrator and gave access on request. These protections cannot be waived. What a landlord may do with property left behind is covered separately from this page.

The termination statute prescribes nothing. There is no required method of delivery for a notice ending a periodic tenancy, no required form, no required content, and subsection (1) does not even say the notice must be in writing. No other Michigan statute supplies a service rule for it. A landlord is therefore left with whatever proof of delivery a court will accept, and the practical advice is to create one, but the law does not say how.

Documents in sequence: Michigan uses two different documents and they are governed differently, which is the point most often got wrong. The notice to quit under the termination statute is what ends the estate, and it is unregulated as described above. The demand for possession under the summary-proceedings chapter is a separate instrument with its own rules, and those rules do not extend backwards to the notice to quit: the service section opens by saying that the demand provided for in the demand section may be served in the listed ways. A demand for possession must be in writing, addressed to the person in possession, give the address or a brief description of the premises, state the reasons for the demand and the time to take remedial action clearly, state the amount due where unpaid rent is claimed, and be dated and signed by the person entitled to possession or their attorney or agent. It may be served by personal delivery to the person in possession, by personal delivery on the premises to a family or household member or an employee of suitable age and discretion with a request that it be passed on, by first-class mail, or by electronic service where the person in possession has specifically consented in writing and the consent or its confirmation was sent by one party and affirmatively replied to by the other; a landlord may not refuse to enter a lease because a prospective tenant declines to consent to electronic service. Where the demand is mailed, the date of service is the next regular mail delivery day after the day it was mailed, which is a rule about when service happens rather than days added to the notice period. In practice one document is often used for both purposes, but the statute does not extend the demand's rules to the notice to quit. The eviction page carries the demand and the court process.

Electronic delivery: the termination statute is silent on it.

What the notice must contain: None for the notice that ends a periodic tenancy. The statute states no form, no required recitals, and no advisory language, and does not require the notice to be in writing at all where the tenancy is at will or by sufferance. The content rules that do exist belong to the separate demand for possession and are described above.

No Michigan termination statute imposes or refers to a federal notice requirement. Federal law appears in the machinery twice, both times as a limit rather than an addition. One of the summary-proceedings grounds, the 7-day route where a tenant has caused or threatened physical injury, does not apply where applying it would violate federal housing regulations. And a local housing commission's own rules, including its published just-cause rules, operate only to the extent they are not inconsistent with federal law or regulation, state law, or a local ordinance. Michigan's own good-cause rule for locally-operated housing works independently of the federal public-housing rules, and the same standard reaches state-assisted multifamily housing through the owner's required written agreement. Michigan has not written any version of the federal 30-day notice for covered dwellings into its own law.

The federal CARES Act 30-day notice to vacate for covered properties, as read in this state's courts: no state appellate decision construes it. No Michigan appellate decision construes the CARES Act's 30-day notice provision. No Michigan statute codifies or narrows the requirement, and the termination statute has not been amended since 2012. The federal provision is unrepealed, so a landlord of a covered dwelling here works from the federal text with no state ruling on how far it reaches. (Appellate picture read as of September 3, 2026.)

Froling v. Bischoff, 73 Mich. App. 496 (Mich. Ct. App. 1977) (Michigan Court of Appeals; arose from a commercial lease; bears on the duty to re-let): Answering the question of who must prove mitigation after a tenant breaks a lease, the court applied the Supreme Court's general contract rule and held that the burden is on the defaulting party to show that the injured party did not use every reasonable effort within its power to minimize the loss, so a landlord suing for the rent does not have to prove having tried. The case arose from a commercial lease of office space, and the rule it applies is the general contract rule rather than one specific to leases.

Klager v. Robert Meyer Co., 95 Mich. App. 319 (Mich. Ct. App. 1980) (Michigan Court of Appeals; arose from a commercial lease; bears on the duty to re-let): The court restated that a landlord has a duty to mitigate damages when a tenant breaks a lease, and that under settled Michigan authority the burden is on the tenant to show, in mitigation of the damages claimed, that the landlord did not use every reasonable effort to minimize them. The case arose from a commercial lease.

Jefferson Development Co. v. Heritage Cleaners, 109 Mich. App. 606 (Mich. Ct. App. 1981) (Michigan Court of Appeals; arose from a commercial lease; bears on the duty to re-let): The court held that a tenant's decision to vacate does not by itself release the tenant, because a release takes the agreement of both parties, and that where a tenant wrongfully leaves the premises the landlord has a duty to use reasonable efforts to mitigate the resulting damages, with the burden on the tenant to establish that the landlord failed to act reasonably. It added that asking a higher rent on re-letting can be evidence of unreasonableness without being a failure in itself, and that a benefit the landlord realizes reduces the tenant's liability. The case arose from a commercial lease of dry-cleaning premises.

Briarwood v. Faber's Fabrics, Inc., 163 Mich. App. 784 (Mich. Ct. App. 1987) (Michigan Court of Appeals; arose from a commercial lease; bears on the duty to re-let): The court held that a landlord's re-entry and use of the space for storage, together with a refusal to extend the lease, did not amount to accepting a surrender where the lease said re-entry was not a termination absent written notice, and that rent from a replacement tenant would only have reduced the landlord's damages rather than ending the original tenant's liability. The case arose from a commercial lease of a mall store.

Fox v. Roethlisberger, 350 Mich. 1 (Mich. 1957) (Michigan Supreme Court; arose from a commercial lease; bears on the duty to re-let): Often cited for the proposition that a Michigan landlord may leave a wrongfully vacated property idle and sue for the whole term, the decision holds nothing of the kind: the court said it did not need to grapple with the question, noted the scarcity of authority, and expressly did not decide either whether the duty exists or where the burden lies. The case arose from a commercial lease of a store building, and it leaves the field to the Court of Appeals decisions that followed.