American Society of Employers (ASE) Releases Preliminary Results to its Drug Testing and Marijuana Legalization Survey

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By: American Society of Employers

American Society of Employers (ASE) Releases Preliminary Results to its Drug Testing and Marijuana Legalization Survey – Employers are Confident in Responding to New Marijuana Law

Media Contact: Heather Nezich, Communications Manager, ASE, 248.223.8040, hnezich@aseonline.org

Livonia, Mich. —November 26, 2018 — The American Society of Employers (ASE), one of the nation’s oldest and largest employer associations, has released a new survey around the legalization of Marijuana in Michigan – its Drug Testing and Marijuana Legalization Survey.  The survey results were released by ASE President & CEO, Mary E. Corrado.

 “ASE has reacted swiftly to this new law with this survey as well as several briefings for our members,” stated Corrado.  “We don’t expect employers to make any sweeping changes to their drug policies and our preliminary results confirm that.”

Michigan is the first Midwestern state to legalize the use of recreational marijuana by a vote of 56% to 44%. What does that mean for Michigan employers? The preliminary data from ASE’s Drug Testing and Marijuana Legalization Survey provides insight into employers’ first thoughts on where their policies and practices currently stand and what changes, if any, they are considering.

183 organizations from across Michigan have participated in ASE’s Drug Testing and Marijuana Legalization Survey.  66% of these organizations are located in the metro Detroit region. 90% of the organizations that responded have 1-500 employees, and nearly 66% of the respondents are classified as manufacturers.

68% of employers have confidence that their organizations’ policies will be able to successfully address their employees’ marijuana usage.  Additional insights include:

  • 15% of employers will likely change their policies, while 51% of employers will not.
  • Of those contemplating change, 42% will remove marijuana testing from their policies altogether, and 31% will ignore any positive marijuana results.
  • Similar to the stance taken with drug testing policies, half of surveyed employers will not consider making changes to their workplace drug or substance abuse polices/practices. 36% remain unsure, and only 14% will consider making a change.

Although the Michigan Regulation and Taxation of Marijuana Act has triggered much interest amongst businesses in Michigan, employers feel confident that their current policies and practices are equipped to handle this new law. “ASE recommends that employers treat marijuana similar to how they treat the use of alcohol amongst employees.  Any substance abuse policies should refer to working while under the influence of marijuana, since it will now be a legal substance similar to alcohol,” stated Mary E. Corrado, ASE President & CEO.  “We don’t advise employers to alter their current polices at this time.”

Some additional points to consider:

  • Workers’ Compensation – Employers will have to consider the impact that their drug testing policies may have on Workers’ Compensation premiums. The removal of marijuana testing could lead to hesitation from the carrier to provide the best rates. This will most certainly lead to higher premiums.
  • Medical Review Officer – When conducting a drug test, results should be certified by a Medical Review Officer who will analyze and validate the results.
  • Safety Sensitive Positions – If an employee is hired into a safety sensitive position, it would be beneficial to continue drug testing, including marijuana.

 

About the American Society of Employers (ASE) – a Centennial Organization

The American Society of Employers (ASE) is a not-for-profit trade association providing people-management information and services to Michigan employers for over 115 years. Since 1902, member organizations have relied on ASE to be their single, cost-effective source for information and support, helping to grow their bottom line by enhancing the effectiveness of their people. Learn more about ASE at www.aseonline.org.

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Federal Appellate Court Reminds Employers That Fourth Amendment Standards Must Support Agency Inspections

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By:  Julia Turner Baumhart, Kienbaum Opperwall Hardy & Pelton, P.L.C.

 

Federal Appellate Court Reminds Employers That Fourth Amendment Standards Must Support Agency Inspections

 

            Employers routinely encounter demands from the alphabet soup of Department of Labor sub-agencies:  OSHA, OFCCP, OWCP, W & H (including FLSA and FMLA variations), among others.  Not always as obvious or recognizable, however, are agency attempts to overreach in their demands.  This is often found in the case of on-site inspections or audits.

            Recently, an Eleventh Circuit federal appellate panel reminded employers that they may be overlooking a basic fundamental right.  Simply because a DOL inspector shows up after a workplace accident or to audit an employee complaint does not entitle the agency to unfettered access to the employer’s premises.  Specifically, in United States v. Mar-Jac Poultry, Inc., the court reminded employers of their Fourth Amendment protection against unreasonable searches.

            The Mar-Jac case arose out of an electrical injury at a poultry processing plant in Georgia.  As required by law, Mar-Jac reported the electrical accident to the Occupational Safety and Health Administration (“OSHA”), the following day.  Several days later, an OSHA inspection team arrived and demanded access, not only to the alleged hazards involved in the accident, but to the entire facility.  Mar-Jac refused access except to the accident site and any tools involved in the accident, but did provide access to certain paperwork including its “OSHA 300 logs,” in which it recorded work-related illness and injuries.  Based on this limited access, OSHA found nine potential OSHA violations, only three of which related to the accident.  The remaining six citations involved areas allegedly common to the poultry processing industry.

            Using these findings, OSHA secured a federal warrant to expand its earlier inspection to again include the entire facility.  Mar-Jac, however, successfully quashed the warrant as to five of the nine potential violations.

            Affirming the lower courts, the Eleventh Circuit again reminded employers that the DOL and its sub-agencies do not have a right to unlimited access to inspect employer premises.  Rather, an agency’s rights extend to two types of on-site inspections or audits.

  • First, the DOL can select the facility based on a general administrative or legislative plan where the selection is based on neutral criteria.
  • The second, and only other basis for inspection, is where the agency has specific identifiable evidence of an existing violation.

While the DOL does not need a warrant to initiate either type of inspection, it must obtain a warrant if the employer refuses to consent on Fourth Amendment grounds, i.e., that the search is not a reasonable one in its inception or scope.  And the required probable cause to overcome the employer’s objection is a higher burden for the government where the agency is relying on the second basis – the specific evidence of an existing violation.  Somewhat higher scrutiny applies to alleged existing violations because, absent legislative or administrative standards, there is a greater possibility that the agency has either targeted the employer or unreasonably expanded the search for purposes of harassment.

            The court agreed in this case that OSHA had unreasonably expanded the search, primarily by using the OSHA 300 logs to equate the existence of a workplace injury or illness with an OSHA violation, without regard to causation.  As the court observed, “the [OSHA] Regulations provide that ‘recording or reporting a work-related injury, illness, or fatality does not mean that the employer or employee was at fault, that an OSHA rule has been violated, or that the employee is eligible for workers’ compensation or other benefits.’”

The same standard pertinent to OSHA audits applies to on-site inspections by the other DOL sub-agencies.  Two caveats to bear in mind, however.  First, once the employer consents to the inspection – whether or not the consent is informed – it probably has waived its Fourth Amendment protection, at least to the extent of its consent.  And second, employers should carefully consider the potential impact on their agency relationships before objecting.  Both caveats suggest a reasoned approach based on fulsome advice and counsel before committing to either path.

This e-blast was written by Julia Turner Baumhart, who is a member of the Detroit SHRM Legal Affairs Committee.  Ms. Baumhart is a partner in the labor and employment firm of Kienbaum Opperwall Hardy & Pelton, P.L.C. in Birmingham, Michigan and can be contacted at jbaumhart@kohp.com or (248) 645-0000. 

 

Detroit SHRM encourages members to share these articles with others, inside and outside their organization, as long as its name and logo, and the author’s information, is included in the re-post of the article.  November 2018. 

 

 

 

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DBusiness names Plunkett Cooney attorneys among Top Lawyers

Plunkett Cooney

 

By: Plunkett Cooney

FOR IMMEDIATE RELEASE

DATE: November 20, 2018

CONTACT: John Cornwell (248) 901-4008

 

DBusiness names Plunkett Cooney attorneys among Top Lawyers

 

Bloomfield Hills, MI — November 20, 2018 —DBusiness magazine recently named 20 metro Detroit attorneys from Plunkett Cooney, one of the Midwest’s oldest and largest law firms, to its 2019 list of “Top Lawyers.”

The DBusiness Top Lawyers list was compiled based on a peer-review survey open to all metro Detroit lawyers. Each year thousands of votes are cast to honor attorneys for excellence in 48 practice areas. There is no commercial relationship to the listings, and no payment is required to be listed and listings cannot be purchased. The list was published in the October/November edition.

Below is a list of the Plunkett Cooney attorney who received the Top Lawyer honor from DBusiness:

Jennifer Andreou (Partner, Detroit) – Medical Malpractice Law
Michael P. Ashcraft, Jr. (Partner, Bloomfield Hills) – Legal Malpractice Law, Professional Malpractice Law
Karen Beach (Associate, Bloomfield Hills) – Appellate Law
Douglas C. Bernstein   (Partner, Bloomfield Hills) – Bankruptcy & Creditor/Debtor Rights Law, Banking & Financial Service Law
Charles W. Browning    (Partner, Bloomfield Hills) – Insurance Law
Dennis G. Cowan           (Partner, Bloomfield Hills) – Land Use & Zoning, Municipal Law
Jeffrey C.  Gerish           (Partner, Bloomfield Hills) – Appellate Law
James R. Geroux           (Of Counsel, Detroit) – Workers Compensation Law
Jeffrey S. Hengeveld    (Partner, Bloomfield Hills) – Legal Malpractice Law
Marc Jerabek                 (Partner, Bloomfield Hills) – Bankruptcy & Creditor/Debtor Rights Law
Robert G. Kamenec      (Partner, Bloomfield Hills) – Appellate Law
Mark S. Kopson             (Partner, Bloomfield Hills) – Health Care Law
David A. Lerner           (Partner, Bloomfield Hills) – Bankruptcy & Creditor/Debtor Rights Law
Mary Massaron              (Partner, Bloomfield Hills) – Appellate Law
Saulius K. Mikalonis      (Senior Attorney, Bloomfield Hills) – Environmental Law
Kenneth C. Newa           (Partner, Bloomfield Hills) – Insurance Law
Stanley A. Prokop          (Of Counsel, Detroit) – Insurance Law
Mary Catherine Rentz    (Partner, Detroit) – Insurance Law
Jeffrey M. Schroder       (Senior Attorney, Bloomfield Hills) – Municipal Law
Matthew J. Stanczyk      (Partner, Detroit) – Product Liability

DBusiness is the region’s only independently-published, general-interest business magazine. It provides timely, local business intelligence and insights to over 150,000 readers, including business owners and decision-makers throughout metro Detroit.

Established in 1913, Plunkett Cooney employs approximately 150 attorneys in eight Michigan cities; Chicago, Illinois; Columbus, Ohio and Indianapolis, Indiana. The firm has achieved the highest rating (AV) awarded by Martindale-Hubbell, a leading, international directory of law firms and is listed among the U.S. News – Best Lawyers “Best Law Firms” in 2018. Plunkett Cooney has also received numerous awards naming the firm as a top place to work within the legal industry.

For more information about Plunkett Cooney’s 2019 DBusiness “Top Lawyers,” contact the firm’s Director of Marketing & Business Development John Cornwell at (248) 901-4008; jcornwell@plunkettcooney.com.

2018 DBusiness Top Lawyers 2019 press release- Academic and Professional Affiliations

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Merces Consulting /MMA Health & Welfare Benefits in MI survey is now available for purchase.

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By: Merces Consulting 

 

“Merces Consulting /MMA Health & Welfare Benefits in MI survey is now available for purchase.  The report contains information from over 150 manufacturing, banking and federally quality health centers.  If you are interested in purchasing a report, please contact Linda Budd, Merces Survey Administrator at 248.721.9561 or by email at lmbudd@mercesconsulting.com.”

Plunkett Cooney named among ‘Best Law Firms’ In America

Plunkett Cooney

 

By: Plunkett Cooney

 

FOR IMMEDIATE RELEASE

Date: November 16, 2018

Contact: John Cornwell (248) 901-4008

 

Plunkett Cooney named among ‘Best Law Firms’ In America

 

Bloomfield Hills, MI — November 16, 2018 — For the 9th consecutive year, Plunkett Cooney, one of the Midwest’s oldest and largest law firms, has been ranked as one of the “Best Law Firms” in the nation by U.S. News and Best Lawyers® for 2019.

 Four of the firm’s offices received tier-one ratings in multiple practice areas. Receiving a tier designation reflects the high level of respect a firm has earned among other leading lawyers and clients in the same communities and the same practice areas for its scope of practice, understanding of business and needs, expertise, responsiveness, integrity, cost-effectiveness, civility and client reference.

“Best Law Firms” rankings are based on a combination of law firm leader and client feedback, independent research, and responses gathered from Best Lawyers peer-reviews. To be eligible for a ranking, a law firm must have at least one lawyer who has received high enough peer-review to be listed in the current edition of Best Lawyers. Firms are eligible in the practice area(s) and metro region(s) in which they have listed lawyers.

Awards were given to law firms in 122 metropolitan areas and eight states based on rankings of more than 14,600 firms in 75 national practice areas. Using a tiered rather than a ranked system, Plunkett Cooney was recognized in the following first- and second-tier metropolitan categories:

  • Metro Detroit
    • Appellate Practice
  • Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law
  • Insurance Law
  • Labor Law – Management
  • Litigation – Construction
  • Mortgage Banking Foreclosure Law
  • Personal Injury Litigation – Defendants
  • Workers’ Compensation Law – Employers
  • Kalamazoo
    • Banking and Finance Law
  • Lansing
    • Litigation – Municipal

Best Lawyers is the oldest and most respected attorney ranking service in the world. For more than 30 years, the Best Lawyers in America list recognizes the top lawyers in each practice area and metropolitan region in the country. U.S. News & World Report is a multi-platform publisher of news and information.

Established in 1913, Plunkett Cooney is a leading provider of transactional and litigation services to clients in the private and public sectors. The firm employs approximately 150 attorneys in eight Michigan cities, Chicago, Illinois, Columbus, Ohio and Indianapolis, Indiana. Plunkett Cooney has achieved the highest rating (AV) awarded by Martindale-Hubbell, another leading, international directory of law firms. The firm was also recently selected by Crain’s Detroit Business as its inaugural Law Firm of the Year winner.

For more information about Plunkett Cooney’s recognition as a 2019 “Best Law Firm,” contact the firm’s Director of Marketing and Business Development John Cornwell at (248) 901-4008; jcornwell@plunkettcooney.com.

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Followup: Nov 6-7 Training + Conference

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By: Michigan Wellness Council 

 

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Nov 6-7 Training + Conference
Exploring Pathways to Positive Workplace Culture

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“This week’s conference was so great, my colleague and I feel bursting with inspiration and new ideas to get rolling. Thank you so much for all your work putting this all together! So valuable!”

On November 6-7, 2018 Michigan Wellness Council hosted a two-day conference. The first day was the workshop training Workplace Wellness that Works (Sponsored by Marsh And McLennan) by Laura Putnam  and the second day were the conference presentations focused on Exploring Pathways to Positive Workplace Culture.

November 6th Pre-Conference Training —Below are links to summaries of the Laura Putnam’s 10 steps of Workplace Wellness that Works and also check out our interview with her on our WellBites podcast:

November 7th Conference Presentations —Below are the links to each set of slides that are available from the conference presenters:

CLOSING KEYNOTE A New Way of Thinking: Wellbeing as the Foundation of Employee Experience by Mindi Cox, Senior Vice President, People & Great Work at O.C. Tanner

NEWS
Save the date: Check out our 2019 Calendar

Membership: Two Is Better Than One! Join Both WELCOA + Michigan Wellness Council And Save

Scholarship: Students apply for the Fred Zimmer Memorial Worksite Wellness Scholarship by Feb 1st

Enjoy your day & Happy Thanksgiving!
Contact: Rita Patel, Executive Director

 

 

 

WAGE SUPPRESSION IN THE U.S.

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By: LERA

 

LERA FALL PROGRAM

SPEAKER:

LARRY MISHEL, PRESIDENT EMERITUS OF THE ECONOMIC POLICY INSTITUTE

TOPIC:

WAGE SUPPRESSION IN THE U.S.

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Your Dose of Vitamin Z

DetZoo

By: Detroit Zoological Society 

 

Make an Impact Today!

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Be a champion for wildlife and make a year-end donation to the Detroit Zoological Society. Your gifts help us provide excellent care for the animals who live at the Detroit Zoo and Belle Isle Nature Center.

Photo Credit: Patti Truesdell

Make a Gift

 

 

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Zoo Hours: Open 362 Days a Year
(Closed Thanksgiving, Christmas and New Year’s Day.)
October through December 31: 10 a.m. to 4 p.m. 

Make Wild Lights a Holiday Tradition!

Beginning November 17

Wild Lights is bigger and brighter this holiday season! Experience the magic during 24 select nights. More than five million LED lights will illuminate trees, buildings and 265 sculptures – more than 220 of which are animals. Buy online and save.

Visit Your Affiliates Store and Purchase Your Wild Lights Tickets Today!

Wild Lights Flyers

Administrators, to assist you in getting the word out about this special offer, access your personalized flyer. Once you log in, click “overlay flyer” located to the left of your screen under “marketing materials” and select the 2018 Wild Lights flyer. If you have forgotten your login ID or password, please contact Jenise Collins at (248) 336-5841 for assistance.

Give the Gift of Vitamin Z

This Holiday Season

When shopping malls become a zoo this holiday season, consider making the Detroit Zoo your shopping destination. A Detroit Zoological Society membership provides a year’s supply of Vitamin Z with free daytime admission to the Detroit Zoo and Belle Isle Nature Center, free parking during public hours and many other benefits. Prices range from $63 to $200. Residents of Wayne, Oakland and Macomb counties receive $10 off all categories and can purchase up to four gift memberships at the discounted rate. Proceeds support the care and welfare of animals at the Detroit Zoo and Belle Isle Nature Center and further our mission of Celebrating and Saving Wildlife. Purchase or renew your membership at your Affiliate Store Today.

Send a Link to This Email

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Zmail is the monthly newsletter of the Detroit Zoological Society. © 2018 Detroit Zoological Society. The Detroit Zoological Society – a renowned leader in humane education, wildlife conservation, animal welfare and environmental sustainability – operates the Detroit Zoo and Belle Isle Nature Center. 

DOL Wage & Hour Stepping Up Reliance on Opinion Letters

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By:  Julia Turner Baumhart, Kienbaum Opperwall Hardy & Pelton, P.L.C

 

DOL Wage & Hour Stepping Up Reliance on Opinion Letters

 

            The Trump Administration’s reinstatement of Wage & Hour Division Opinion Letters – a practice suspended during the Obama Administration – is gaining momentum.  On November 8, 2018, the Department of Labor issued four Opinion Letters on a variety of topics ranging from tipped employee wage credits to much narrower topics.

            The most encompassing Opinion Letter – that dealing with tip credits under the Portal-to-Portal Act – reissued a letter issued in the closing moments of the George W. Bush Administration that the successor administration promptly mothballed.  The new letter – FLSA 2018-27 – reissued the old letter virtually verbatim to distinguish between tipped employees in dual jobs (where one job is a tipped occupation but not the other) and tipped employees who perform both tip-generating and non-tip generating duties.

            In the case of dual jobs, the letter clarifies what should be common sense: the employer may take a tip credit only for those hours spent performing the tipped job.  The letter provides the example of the hotel maintenance employee who also serves as a hotel waiter.  The FLSA would require the hotel to pay minimum wage for any hours worked in maintenance but allow the hotel to take advantage of a tip credit for hours spent as a waiter – a bright line test.

            The standard applied to tipped employees who also perform non-tipped duties presents a much fuzzier line.  The letter provides the example of the waiter who also spends time in non-tip generating duties such as cleaning and setting tables, toasting bread, making coffee, occasionally washing dishes or glasses, or vacuuming before or after closing.  Earlier guidance implied that, under the above circumstances, any allocation of non-tipped duties that exceeded 20 percent of working time could not be eligible for a tip credit.

            Opinion Letter 2018-27 rejects the 20 percent ceiling on non-tipped duties as imposing an unrealistic burden to monitor and track minute-by-minute job performance.  Rather, the new standard allows credit for duties listed as core or supplemental to the specific tip-producing occupation on the Occupational Information Network (O*NET) or in 29 C.F.R. § 531.56(e), provided the duties are performed contemporaneously with or immediately before or after duties directed at serving customers.  The specific occupational duties considered core or supplemental for each tipped occupation can currently be found at https://www.onetonline.org/ link/summary/35-3031.00.

            Another November 8 Opinion Letter, FLSA 2018-25, addresses when exempt salaried employees may receive additional hourly compensation for hours worked without endangering the exemption.  The opinion letter addresses engineers and senior designers, classified as professional salaried employees, who receive a guaranteed weekly salary of $2,100, regardless of the number of hours worked during the week.  However, those employees also could earn $70 for every hour worked in excess of 30 per week.  As a result, some engineers were earning a weekly average salary of up to $3,761.

            Opinion Letter 2018-25 provides that the guaranteed weekly – or “usual” – salary has to bear a reasonable relationship to the amount actually paid.  A reasonable relationship exists provided the average weekly salary does not exceed 1.5 times the usual salary.  Moreover, the ratio has to be determined on an employee-by-employee basis.  Under the circumstances presented, the usual or guaranteed salary of $2,100 per week would support an average actual salary of up to $3,150.  Presumably, then, the employer would need to increase  the usual or guaranteed weekly salary of any engineer or senior designer whose average actual salary exceeded $3,150 to avoid endangering the exempt status of that employee.

            The remaining two opinion letters deal with narrower topics.  One addresses when swimming pool or similar recreational operators supporting multi-faceted operations, such as hotels and apartment complexes, are entitled to claim relief from wage and hour laws as seasonal amusement or recreational establishments.  For this to occur, according to FLSA 2018-26, those in the employer’s employ must work at (1) an establishment; (2) frequented by the public, including for a non-prohibitive fee; (3) that is for amusement and recreation.

            The fourth letter is narrower still, answering the question of whether a nonprofit, private volunteer fire department contracting with a state or local government to provide fire protection services to the public can benefit from the partial exemption from overtime requirements applicable to employees of public agencies.  This Opinion Letter, FLSA 2018-24, concludes that private fire departments that are not directly responsible to public officials or the general public and who are designated in their contracts as independent contractors do not qualify for the partial exemption.  This is true even if the department receives partial funding from a state or locally imposed fee.

This e-blast was written by Julia Turner Baumhart, who is a member of the Detroit SHRM Legal Affairs Committee.  Ms. Baumhart is a partner in the labor and employment firm of Kienbaum Opperwall Hardy & Pelton, P.L.C. in Birmingham, Michigan and can be contacted at jbaumhart@kohp.com or (248) 645-0000. 

 Detroit SHRM encourages members to share these articles with others, inside and outside their organization, as long as its name and logo, and the author’s information, is included in the re-post of the article.  November 2018. 

Plunkett Cooney Named Law Firm of the Year Press Release 2018

Plunkett Cooney

 

By: Plunkett Cooney

 

FOR IMMEDIATE RELEASE
DATE:  November 2, 2018
CONTACT:  John E. Cornwell (248) 901-4008

 

Plunkett Cooney named business publication’s ‘Law Firm of the Year’

 

BLOOMFIELD HILLS, Mich. – November 2, 2018 – Plunkett Cooney – one of the Midwest’s oldest and largest law firms – has been selected “Law Firm of the Year” by Crain’s Detroit Business (Crain’s).

Following an extensive review conducted by a board comprised of Metro Detroit legal and business professionals working in conjunction with the special projects editor for Crain’s, Plunkett Cooney was selected the first ever winner of the Law Firm of the Year honor.

“I can’t tell you how proud all of the men and women of Plunkett Cooney are about receiving this honor,” said Plunkett Cooney’s President & CEO Tom Vincent. “It’s a validation of the hard work, expertise and results our attorneys and staff achieve from the boardroom to the courtroom to the community. We’ve always known that ours is a great law firm, but it’s nice to be acknowledged by such a prestigious publication like Crain’s.”

The firm’s selection as Law Firm of the Year was based on trial verdicts, impactful litigation, appellate decisions and noteworthy business deals in 2017 and 2018. The honor was announced in the Oct. 29 edition of the business news publication.

Established in 1913, Plunkett Cooney employs nearly 300 employees, including approximately 150 attorneys in eight Michigan cities, as well as in Chicago, Illinois, Columbus, Ohio and

Indianapolis, Indiana. The firm, which provides a range of transactional and litigation services, has achieved the highest rating (AV) awarded by Martindale-Hubbell. For eight consecutive years, U.S. News and Best Lawyers have also named Plunkett Cooney among its top commercial law firms in the United States.

Additionally, Plunkett Cooney was honored earlier this year by the National Law Journal as being among the top law firms nationally for female attorney diversity. The firm has also previously received state wide honors for being among the top places to work.

For more information about Plunkett Cooney’s “Law Firm of the Year” honor, contact the firm’s Director of Marketing & Business Development John Cornwell at (248) 901-4008 or jcornwell@plunkettcooney.com.

 

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