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Michigan Supreme Court to Hear Whether South Haven Can Be Held Liable After Teen Drowned at Public Beach

The Michigan Supreme Court will hear arguments on whether the city of South Haven enjoys governmental immunity in a wrongful death lawsuit after an 18-year-old drowned at a public beach in 2020. The case centers on whether beach operations count as a governmental function or a proprietary business activity.

Michigan Capitol|April 9, 2026|3 sources cited

The Legal Question

The Michigan Supreme Court will hear oral arguments in a wrongful death case that could reshape how municipalities are held accountable for deaths at public beaches.

The court ordered arguments to focus on whether the lower court correctly ruled that South Haven enjoys governmental immunity from liability.

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

A Family's Fight

Crystal LeDuke filed a wrongful death lawsuit against The City of South Haven in May 2024 after her 18-year-old son Brandon Chambers drowned while swimming at a city beach in 2020.

Chambers, of the Jackson area, had been swimming with friends when he struggled. One of the friends was successfully rescued, but Chambers went under.

The drowning incident occurred in the summer of 2020 at a South Haven beach. The lawsuit was filed later that year by the victim's family.

The Immunity Battle

Since the initial filing, city officials have been trying to dismiss the lawsuit on grounds of governmental immunity — a law that renders government agencies immune from liability "if the governmental agency is engaged in the exercise or discharge of a governmental function."

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A Van Buren County court denied the city's initial request for dismissal in June 2024, a decision the Michigan Court of Appeals overturned in September 2025.

The point of debate is whether the 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.

Why It Matters

In granting South Haven governmental immunity, the Michigan Court of Appeals concluded that the city's beach operations do not quality as a proprietary function because they do not operate their beaches for profit, and rather, as a government function.

The city doesn't disagree that the beaches generate profit, however, they maintain that those funds aren't used for anything other than maintaining the beaches and do not fund any other "business-type activities" such as roads, parks or utilities.

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

Michigan Court of Appeals Judge Hon. P.J. Patel issued a dissenting opinion when the court granted South Haven governmental immunity.

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

What's Next

The Michigan Supreme Court is expected to issue a ruling in the case by the end of 2026, which will determine whether the city of South Haven can be held liable for the drowning death or if government immunity protects the municipality from such lawsuits.

The takeaway: This tragic drowning case highlights the complex legal issues surrounding government liability and the duty of care owed by public entities to ensure the safety of citizens using taxpayer-funded recreational facilities like beaches.

governmental immunitySouth Havenbeach safetywrongful deathMichigan Supreme Court

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