Couch v. Schultz

In Couch v. Schultz, 193 Mich App 292; 483 NW2d 684 (1992), the decision relied on by the circuit court in the present case, this Court granted witness immunity to a corrections officer who filed a misconduct report against two prisoners resulting in a finding of misconduct at a prison disciplinary hearing. Id. at 293. The issue in that case was not whether witnesses are granted immunity, but whether the prison discipline hearing was a "judicial proceeding" for which witness immunity would extend. Id. The Court did not consider or discuss the availability of witness immunity generally because "it is well settled in Michigan that statements made during the course of legislative proceedings, statements made during the course of judicial proceedings, and communications by military and naval officers are absolutely privileged." Id. at 294.