People v. Mungo

holding that “[w]here a cause of action is not provided at law” the plaintiff must have “a special injury” “different from the citizenry at large” | stating that the focus is on whether a litigant is the proper party to request adjudication of a particular issue | stating that the focus is on whether a litigant is the proper party to request adjudication of a particular issue | holding labor organizations have standing to bring actions where they have "a substantial and distinct interest" | finding that teachers had standing to seek injunctive relief under state law to expel students who had allegedly assaulted them | holding that even in the absence of a legal cause of action, “[a] litigant may have standing ... if the litigant has a special injury or right, or substantial interest, that will be detrimentally affected in a manner different from the citizenry at large” | stating that "strictly interpreting the judicial power of Michigan courts to be identical to the federal court's judicial power does not reflect the broader power held by state courts" | stating that the “essential requirement of the term ‘actual controversy’ under [MCR 2.605] is that plaintiffs plead and prove facts which indicate an -8- adverse interest necessitating the sharpening of the issues raised” | overruling Lee v Macomb Co Bd of Comm’rs, 464 Mich 726; 629 NW2d 900 [2001] | “[W]henever a litigant meets the requirements of MCR 2.605, it is sufficient to establish standing to seek a declaratory judgment” | “The standing inquiry focuses on whether a litigant is a proper party to request adjudication of a particular issue and not whether the issue itself is justiciable.” | “the standing inquiry focuses on whether a litigant ‘is a proper party to request adjudication of a particular issue and not whether the issue itself is justiciable’ ” | a litigant has standing if he or she has a special injury or right or has a substantial interest that will be detrimentally affected in a manner different from the citizenry at large