21 April 2025

An unclaimed property examiner must complete the exam (not merely start the exam) of a holder within the statute of limitations, the Michigan Supreme Court ruled in Dine Brands Global, Inc. v. Eubanks; The Walt Disney Company v. Eubanks, Nos. 165391 and 165392 (Mich. March 24, 2025). The ruling is significant because it puts a limit on the seemingly never-ending examination process. The significance of the constraint will depend on an issue remanded to the Michigan Court of Appeals for further consideration (i.e., whether a demand for payment at the end of an audit creates a new, independent legal obligation separate from the original duty to report and remit unclaimed property). 

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