[5] The Education Department dismissed the case using the previously established 'hostile environment' standard.

[6] Over the years, MDCR has produced a number of issue papers and policy documents.

In January 2013, the department issued the Report on LGBT Inclusion Under Michigan Law for the commission to review.

[8] The same year, an "uproar" occurred after the civil rights commission, which oversees the department, unanimously voted to pay a $24,740 bonus to department executive director Agustin Arbulu in a secret meeting that violated Michigan's open meetings law.

[9][10] The commission ultimately agreed to "redo the bonus vote" in open session.