Mich. Ct. R. 7.215
Staff Comment: An unpublished opinion may be cited, for example, if there is no published authority on a given legal proposition or if it is necessary to demonstrate a conflict in interpretation of the law. The changes in MCR 2.119 and MCR 7.212 provide cross-references to MCR 7.215(C).
The staff comment is not an authoritative construction by the Court. In addition, adoption of a new rule or amendment in no way reflects a substantive determination by this Court.