In Denham v. University of Michigan, 151 Mich. App. 77; 390 N.W.2d 204 (1986) the Court addressed reinstatement in the context of a motion for rehearing of the original decision to dismiss the case. The trial court ruled that reinstatement was inappropriate because the plaintiff asking to reinstate the case had failed to demonstrate: (1) that the lack of progress was not her fault and; (2) that she had acted diligently while the action was pending. Denham, 151 Mich. App. at 80. On appeal, the Denham Court reversed the decision of the trial court because the trial court had erred in dismissing the action for lack of progress, but the Denham Court did not explicitly criticize the criteria the trial court applied to the issue on rehearing. Denham, 151 Mich. App. at 81-82. Denham actually says: Plaintiff's case was originally dismissed because plaintiff failed to appear at the time of the general "no progress" call. However, upon rehearing, plaintiff's case was dismissed because the Court of Claims judge found that plaintiff had failed to show that the lack of progress in the case was not due to fault or lack of due diligence on her part. Id. at 80. Certainly, it is debatable whether the trial court's decision in Denham was equivalent to denying a motion for reinstatement. After all, the appellate decision does not make clear whether the court entered an order dismissing the action when the plaintiff failed to appear at the no-progress call. Nevertheless, the logic applied in Denham appears to apply equally well in the reinstatement context.