Michigan Supreme Court to Decide Whether South Haven Has Immunity in Beach Drowning Lawsuit

18-Year-Old Drowned at Lake Michigan Beach in 2020, Family Sues City

The Michigan Supreme Court will decide whether the City of South Haven can be held liable in a wrongful death lawsuit after an 18-year-old drowned at a city beach while swimming in Lake Michigan.

Brandon Chambers, 18, died in September 2020 after swimming at South Haven's public beach. His mother Crystal LeDuke filed a wrongful death lawsuit against the city in May 2024, alleging that the city failed to provide adequate safety measures and lifeguard supervision.

The Michigan Court of Appeals ruled in September 2025 that South Haven has governmental immunity, granting the city protection from liability. The state Supreme Court is now reviewing whether that decision stands.

Governmental Immunity Is at Stake

The case centers on a legal question that could affect how Michigan municipalities manage public beaches and recreational facilities.

Under Michigan law, governmental agencies are immune from tort liability when they carry out governmental functions. The exception is when the activity qualifies as a proprietary function, or business-type activity that is not a governmental function.

The lower court concluded that the city's beach operations do not qualify as a proprietary function because they do not operate for profit. South Haven officials maintain that beach funds are used only for maintaining the beaches and do not fund other business-type activities such as roads, parks or utilities.

But questions remain about the city's financial records and whether money from their beach fund truly is used only for beach operations.

What the Michigan Supreme Court Is Hearing

The Michigan Supreme Court agreed on Friday to consider hearing arguments about whether The City of South Haven has governmental immunity in the wrongful death lawsuit.

The justices are examining whether the beach operations qualify as a governmental function or a proprietary function that would expose the city to liability.

"This case will have major implications for how municipalities approach public safety at beaches and other recreational areas under their jurisdiction."

Samantha Wilkins, Legal Analyst

The ruling is expected by the end of 2026 and could set an important legal precedent regarding the scope of government immunity and the responsibility of public entities to ensure the safety of beachgoers.

Why This Matters for Michigan

South Haven is a lakeside city on the eastern shore of Lake Michigan known for its public beaches that attract many tourists each summer. The case could affect how other Michigan municipalities manage similar recreational facilities.

The decision will determine whether the city can be held liable for the drowning death or if governmental immunity protects the municipality from such lawsuits.

The case also raises broader questions about the duty of care owed by public entities to ensure the safety of citizens using taxpayer-funded recreational facilities like beaches.

The Legal Battle

Since the initial filing, city officials have been trying to dismiss the lawsuit on grounds of governmental immunity. The Michigan Court of Appeals granted South Haven governmental immunity in September 2025, a decision that overturned a June 2024 ruling by a Van Buren County court that denied the city's initial request for dismissal.

The point of debate is whether the city's beach operations qualify as a proprietary function, or business-type activity, an exception to governmental immunity protections that would open up the city to liability in Chambers' death.

On the other side of the argument, there are questions about the city's financial records and whether money from their beach fund truly is used for beach operations only.

The Michigan Supreme Court is now weighing these competing arguments and will issue a ruling that could reshape how Michigan courts interpret governmental immunity in cases involving public recreational facilities.

Sources:

• WWMT: Michigan Supreme Court agrees to possibly consider South Haven immunity in drowning suit
• Law360: Mich. Justices To Weigh Beach Profit Immunity Dispute
• South Haven Today: Lake Michigan Drowning Lawsuit Heads to State Supreme Court