Cockels v. Int'l Business Expositions, Inc

In Cockels v. Int'l Business Expositions, Inc, 159 Mich. App. 30, 35; 406 N.W.2d 465 (1987), the Court determined that while the plaintiff did not expressly allege a violation of the act, the clear implication of the pleadings indicated that the plaintiff, indeed, was alleging such a violation. Therefore, the Court found the plaintiff to be without recourse in the trial court because the plaintiff did not exhaust her administrative remedies. Id. at 36. The Court found that the act required a plaintiff to seek redress through the Department of Labor before pursuing a remedy in the circuit court. Id. The Cockles Court did not make a determination whether a separate common-law claim filed in conjunction with this statutory claim would need to be resolved through the administrative remedies provision of the WFBA.