Michigan Form DC 104, titled Verification of Military Service Status, is the SCAO-approved court form that a plaintiff (usually a landlord or creditor) files in a Michigan district court to confirm whether the defendant is on active military duty before the judge can enter a default judgment. The form exists because the federal Servicemembers Civil Relief Act (SCRA), 50 U.S.C. ยง 3931 blocks default judgments against active-duty servicemembers unless the court has a sworn statement about the defendant’s military status.
Filing DC 104 sounds simple, but a single wrong checkbox can trigger a federal penalty of up to one year in jail for a knowingly false affidavit under 50 U.S.C. ยง 3931(c). The Department of Defense SCRA database processes more than 30 million status checks per year, and Michigan district courts reject thousands of default judgment requests every year for missing or incomplete DC 104 affidavits, according to the State Court Administrative Office (SCAO).
Here is what you will learn in this guide:
- ๐ What Form DC 104 is, who must file it, and how it ties into the Michigan Court Rules (MCR 2.603 and MCR 4.201).
- โ A complete line-by-line walkthrough of every box, signature line, and certification on the current (3/19) revision.
- ๐งพ Three fully filled-out scenarios โ a nonpayment eviction, a land contract forfeiture, and an SCRA-protected tenant โ with example entries.
- ๐๏ธ How to file DC 104 through MiFILE, by mail, in person, and (where allowed) by fax, plus the exact proof-of-filing to keep.
- โ ๏ธ The top 10 mistakes that cause Michigan district courts to deny default judgment, and how to avoid each one.
What Form DC 104 Is and Who Must File It
Form DC 104 is the sworn affidavit a Michigan district court requires before it can sign a default judgment against a defendant who failed to answer a summary proceedings complaint, a small claims case, or a civil action. It is governed by MCR 2.603(B)(1) and the federal SCRA. The form was last revised 3/19, so always confirm you are using the current SCAO version from the Michigan Courts forms library before you sign.
The filer is the plaintiff in the case, or the plaintiff’s attorney. In most Michigan filings, that means the landlord in an eviction (summary proceedings) case, the vendor in a land contract forfeiture, the creditor in a small claims case, or the plaintiff in any general civil matter where the defendant has not appeared. The defendant never files DC 104 โ it is a one-sided affidavit by the moving party.
The form solves a specific federal problem. Under 50 U.S.C. ยง 3931(b)(1), a court cannot enter a default judgment until the plaintiff files a sworn statement either confirming the defendant is not in military service, confirming the defendant is in military service (which triggers a mandatory 90-day stay), or stating the plaintiff was unable to determine military status. DC 104 is Michigan’s standardized way to deliver that sworn statement.
DC 104 is jurisdiction-neutral within Michigan. All 83 counties and every Michigan district court accept the same SCAO form, although a handful of high-volume courts like the 36th District Court in Detroit and the 46th District Court in Southfield post local administrative orders that require e-filing through MiFILE. Federal courts sitting in Michigan use their own SCRA declaration, not DC 104.
Before You Start: Documents and Information You Need
Gather every piece of data before you open the form. Filing an incomplete affidavit, or one that contradicts the underlying complaint, is the fastest way to get a default judgment denied under MCR 2.603. The Michigan Legal Help self-help center recommends assembling the full case file first.
- Case number and court name. Pulled directly from your file-stamped DC 102 Complaint, Nonpayment of Rent or DC 100 series complaint. A mismatched case number routes your filing to the wrong file and delays judgment.
- Defendant’s full legal name and last known address. Must match the summons exactly, including middle initials and suffixes, or the SCRA database will not return a clean match.
- Defendant’s date of birth and Social Security number (if available). The DoD SCRA single-record request returns more accurate results when DOB or SSN is provided, although neither is mandatory.
- DoD SCRA Military Status Report (printout). Generated free of charge from the DMDC SCRA portal, this PDF is the evidentiary backbone for the affidavit.
- Source of your knowledge. Whether you spoke with the tenant, ran the DMDC search, or relied on a process server’s affidavit, you must be able to articulate exactly how you know what you know.
- Plaintiff’s identity and signing authority. If you are signing as an agent (e.g., property manager), have a written authorization from the owner ready in case the court asks.
- Notary or court clerk access. DC 104 must be signed under oath, so plan your notary visit, MiFILE remote notarization, or in-person clerk verification before deadline day.
- Underlying notice documents. Have the Notice to Quit (DC 100c), lease, and proof of service of the summons handy in case the judge asks during the default hearing.
- Default request form (DC 105/MC 07). DC 104 almost always travels with the Default Request, Affidavit, and Entry (MC 07), so prepare both at once.
Where to Get the Form and How to Access It
The official, fillable PDF lives on the SCAO forms page under the Landlord-Tenant / Land Contract and General Civil categories. The direct link to the current 3/19 revision is the DC 104 PDF, which opens in any standard PDF reader and lets you type into the fillable fields.
Paper copies are available free at every district court clerk’s office in Michigan. Courts like the 17th District Court in Redford and the 54-A District Court in Lansing keep a stack in the lobby. Some county legal aid clinics, such as Lakeshore Legal Aid and Legal Services of Eastern Michigan, can hand you a printed copy if you walk in.
Avoid third-party PDF mills. Old revisions floating on private real-estate-investor blogs lack the current SCRA language and will get rejected on sight by experienced clerks. If you see a revision date older than 3/19 on the bottom-left corner of the form, throw it out and download fresh.
The form is one page, double-sided in some printings, and contains a case caption block, a numbered affidavit body, a signature block, and a notary jurat. The fillable PDF preserves the layout, so what you type on screen lines up with what prints on paper.
Step-by-Step: How to Fill Out Form DC 104 Line by Line
The form breaks into four logical blocks: the case caption, the affidavit statements, the signature block, and the notary jurat. Work top to bottom and do not skip any field, even ones that look optional. SCAO clerks routinely reject affidavits with blank fields.
Court Name and County (Top Caption Bar)
What the field asks in plain English. The top bar asks which Michigan district or municipal court is hearing the case and what county it sits in.
How to answer it. Copy the court name and county exactly as printed on the summons and complaint, in ALL CAPS, including the court number (e.g., 36TH DISTRICT COURT, WAYNE COUNTY).
A specific example answer. Landlord Maria Lopez writes 36TH DISTRICT COURT on the court line and WAYNE on the county line.
A nuance or edge case. If you filed in a municipal court that shares jurisdiction with a district court (rare, but Grosse Pointe Farms, Grosse Pointe Park, Grosse Pointe Shores, and Grosse Pointe Woods still operate municipal courts), use the municipal court’s exact name from the Michigan Courts directory.
A common mistake on this field and its direct consequence. Writing the wrong district number (e.g., 35TH instead of 36TH) sends your affidavit to the wrong court mailbox and the default request dies in limbo.
A misconception people hold about this field. Filers think circuit court and district court are interchangeable. They are not โ DC 104 is a district court form, and writing CIRCUIT COURT invalidates the caption.
Court Address and Telephone Number
What the field asks in plain English. It wants the physical street address and main phone number of the court where the case is filed.
How to answer it. Use the address printed on the summons, not a P.O. box. Include the telephone number with area code in the format (313) 965-8888.
A specific example answer. Maria writes 421 Madison Ave., Detroit, MI 48226 and (313) 965-8888.
A nuance or edge case. Multi-location district courts (the 41-B in Clinton Township and the 41-A in Shelby Township) require the specific branch address, not the administrative headquarters.
A common mistake on this field and its direct consequence. Using the clerk’s mailing P.O. box instead of the street address. The judge cross-checks this against the court’s official record and a mismatch can trigger a clerk’s notice to refile.
A misconception people hold about this field. Many filers assume the address is cosmetic. It is not โ the court uses it to confirm venue under MCL 600.8312.
Case Number Box
What the field asks in plain English. It is asking for the case number assigned when the original complaint was filed.
How to answer it. Copy the case number exactly as stamped on the summons, including the year prefix, the case type code, and any suffix letters (e.g., 26-12345-LT).
A specific example answer. Maria writes 26-12345-LT because her case is a 2026 landlord-tenant matter.
A nuance or edge case. If your case was reassigned to a different judge after filing, the case number stays the same โ do not change it to reflect the new judge’s docket.
A common mistake on this field and its direct consequence. Dropping the case type suffix (writing 26-12345 instead of 26-12345-LT). The clerk’s docketing system will not find the file and your affidavit sits unprocessed.
A misconception people hold about this field. Filers think the case number is auto-generated by MiFILE. It is not โ you type it manually, and MiFILE will reject the e-file if the number does not match the master case.
Plaintiff’s Name and Address (Left Caption Block)
What the field asks in plain English. This is the moving party โ usually you, the landlord or creditor โ and your service address.
How to answer it. Enter the plaintiff’s full legal name (individual or business entity) as it appears on the complaint, followed by the address where court papers should be mailed.
A specific example answer. MARIA LOPEZ, 2200 W. Grand Blvd., Detroit, MI 48208.
A nuance or edge case. If the plaintiff is an LLC, write the full registered name from LARA’s Corporations Online Filing System, e.g., LOPEZ HOLDINGS, LLC.
A common mistake on this field and its direct consequence. Using a doing-business-as name without the legal entity (writing Lopez Rentals instead of Lopez Holdings, LLC dba Lopez Rentals). A non-matching plaintiff name can void the judgment under MCR 2.201.
A misconception people hold about this field. Filers believe a property manager can substitute their own name. They cannot โ the plaintiff must remain the legal owner or assignee.
Plaintiff’s Attorney Block (Bar No., Address, Phone)
What the field asks in plain English. If a lawyer represents the plaintiff, fill in the attorney’s name, State Bar of Michigan P number, address, and phone.
How to answer it. Enter the attorney’s name as licensed (e.g., JOHN P. SMITH (P12345)), followed by firm address and phone.
A specific example answer. JOHN P. SMITH (P54321), 100 Renaissance Center, Detroit, MI 48243, (313) 555-1212.
A nuance or edge case. Pro se plaintiffs leave this block blank โ do not write N/A across it, just leave it empty so the clerk knows the plaintiff is self-represented.
A common mistake on this field and its direct consequence. Missing P number. Without the bar number, MiFILE will block the e-filing entirely.
A misconception people hold about this field. Filers think only the attorney can sign DC 104. The plaintiff can sign it directly; the attorney block is purely informational when counsel of record exists.
Defendant’s Name and Address (Right Caption Block)
What the field asks in plain English. Who you are seeking a default against, and where they were served.
How to answer it. Use the defendant’s full legal name and last known residential or business address โ the same one on the summons return of service.
A specific example answer. JAMES R. ANDERSON, 5400 Cass Ave., Apt. 4B, Detroit, MI 48202.
A nuance or edge case. If you served multiple defendants, you need a separate DC 104 for each defendant because the SCRA inquiry is individualized.
A common mistake on this field and its direct consequence. Listing a forwarding address instead of the address served. The court’s record must show the defendant was given proper notice at the served address, and a mismatch supports a motion to set aside the default under MCR 2.603(D).
A misconception people hold about this field. Filers think they can leave the address blank if the tenant has vacated. They cannot โ the field memorializes service, not current residence.
Paragraph 1 โ Statement of Knowledge
What the field asks in plain English. Paragraph 1 is your sworn statement of how you personally know whether the defendant is in the military.
How to answer it. Briefly describe your basis โ running the DMDC SCRA report, personal contact with the defendant, employment records, etc. Keep it factual.
A specific example answer. I conducted a Department of Defense Manpower Data Center SCRA database search on 5/15/2026 using the defendant’s name and date of birth.
A nuance or edge case. If you have multiple sources (DMDC report and personal conversation), list both โ the court favors layered evidence.
A common mistake on this field and its direct consequence. Writing I just know or informed and belief. SCRA case law, including Gordon v. Pete’s Auto Service of Denbigh, demands a fact-specific basis, and vague language can void the judgment.
A misconception people hold about this field. Filers believe “knowledge” can be third-hand. SCRA requires firsthand or documentary knowledge โ hearsay is not enough.
Paragraph 2 โ Military Status Determination (the Three Boxes)
What the field asks in plain English. You must check one and only one of three boxes: defendant is not in military service, defendant is in military service, or you are unable to determine.
How to answer it. Check the box that matches your DMDC result and attach the DMDC printout as evidence.
A specific example answer. Maria’s DMDC report comes back negative, so she checks โ is not in the military service of the United States.
A nuance or edge case. If the defendant is a recent veteran (discharged within 90 days), they still get SCRA protection under 50 U.S.C. ยง 3911, so check the is in military service box and request the mandatory 90-day stay.
A common mistake on this field and its direct consequence. Checking unable to determine when DMDC actually returned a clean result. This triggers the court to appoint counsel for the defendant at the plaintiff’s expense under 50 U.S.C. ยง 3931(b)(2).
A misconception people hold about this field. Filers think Reserves don’t count. Active Reserve and National Guard members called to federal duty are fully covered by the SCRA.
Signature Line and Date
What the field asks in plain English. Your sworn signature and the date you signed.
How to answer it. Sign in blue or black ink in front of a notary, and write the date in MM/DD/YYYY format.
A specific example answer. Maria Lopez signs and dates 05/20/2026.
A nuance or edge case. MiFILE accepts /s/ Maria Lopez electronic signatures only when paired with a remote online notarization under MCL 55.261 et seq..
A common mistake on this field and its direct consequence. Signing before reaching the notary. A pre-signed jurat is void, and the court will strike the affidavit.
A misconception people hold about this field. Filers think a digital signature image is the same as a notarized e-signature. It is not โ the notary must witness the act.
Notary Jurat Block
What the field asks in plain English. The notary public’s certification that you signed under oath.
How to answer it. Let the notary complete this โ they fill in the county, date, their printed name, signature, commission expiration, and seal.
A specific example answer. Notary writes Sworn to before me on 05/20/2026 in Wayne County, Michigan. /s/ Tracy Nguyen, Notary Public, Commission expires 11/14/2028.
A nuance or edge case. Out-of-state notarization is allowed under MCL 55.293 if the notary is commissioned in their home state.
A common mistake on this field and its direct consequence. Missing commission expiration date. Michigan courts treat this as a defective jurat and will reject the affidavit per MCR 1.109(D)(3).
A misconception people hold about this field. Filers think any notary will do. Some courts (Oakland County’s 48th District Court is strict here) require notarization within Michigan unless an apostille is attached for out-of-state jurats.
Three Filled-Out Examples Using Real Scenarios
Scenario 1: Maria Lopez โ Nonpayment of Rent Eviction
Maria owns a Detroit duplex and is evicting tenant James Anderson for $4,800 in unpaid rent.
| Form Section | What Maria Enters |
|---|---|
| Court name | 36TH DISTRICT COURT |
| County | WAYNE |
| Case number | 26-12345-LT |
| Plaintiff | MARIA LOPEZ, 2200 W. Grand Blvd., Detroit, MI 48208 |
| Defendant | JAMES R. ANDERSON, 5400 Cass Ave., Apt. 4B, Detroit, MI 48202 |
| Paragraph 1 (knowledge) | DMDC SCRA search performed 05/15/2026 using DOB 03/14/1985 |
| Paragraph 2 (status) | โ is not in the military service of the United States |
| Signature/Date | Maria Lopez, 05/20/2026 |
| Notary block | Notarized by Tracy Nguyen, Wayne County, commission expires 11/14/2028 |
Scenario 2: Carlos Rivera โ Land Contract Forfeiture
Carlos, a vendor on a 2019 land contract, is forfeiting against vendee Aisha Brown after 90 days of missed payments under MCL 600.5726.
| Form Section | What Carlos Enters |
|---|---|
| Court name | 52-1 DISTRICT COURT |
| County | OAKLAND |
| Case number | 26-77821-LC |
| Plaintiff | CARLOS RIVERA, 18 Maple Lane, Novi, MI 48374 |
| Defendant | AISHA BROWN, 412 Pine St., Walled Lake, MI 48390 |
| Paragraph 1 (knowledge) | DMDC SCRA report run 05/12/2026; also confirmed civilian employment with Beaumont Health HR on 05/13/2026 |
| Paragraph 2 (status) | โ is not in the military service of the United States |
| Signature/Date | Carlos Rivera, 05/18/2026 |
| Notary block | Notarized by Linda Park, Oakland County, commission expires 04/02/2027 |
Scenario 3: Janet Cole โ SCRA-Protected Tenant
Janet, a small landlord in Lansing, learns that her tenant Marcus Hill is on active duty Army assignment in Fort Hood.
| Form Section | What Janet Enters |
|---|---|
| Court name | 54-A DISTRICT COURT |
| County | INGHAM |
| Case number | 26-04567-LT |
| Plaintiff | JANET COLE, 700 Allegan St., Lansing, MI 48933 |
| Defendant | MARCUS T. HILL, 219 Kalamazoo St., Lansing, MI 48912 |
| Paragraph 1 (knowledge) | DMDC SCRA report dated 05/10/2026 confirms active duty since 02/01/2025 |
| Paragraph 2 (status) | โ is in the military service of the United States โ 90-day stay requested |
| Signature/Date | Janet Cole, 05/19/2026 |
| Notary block | Notarized by Robert Singh, Ingham County, commission expires 08/22/2026 |
How to File the Completed Form
Michigan offers four filing channels, but the trend across district courts is mandatory e-filing through MiFILE. Confirm your specific court’s filing rules at the Michigan eFiling portal.
- MiFILE (online): Upload the signed, notarized PDF along with the MC 07 Default Request. There is no separate filing fee for DC 104 because it rides on the underlying case. MiFILE accepts Visa, Mastercard, Discover, and ACH. Processing usually takes 1โ3 business days. Save the MiFILE confirmation email as proof of filing.
- In person at the clerk’s office: Walk the signed original to the court address listed on the summons. No fee. Cash, check, or money order accepted for any related fees on the default request. Same-day docketing in most courts. Ask the clerk to stamp a copy as your file-stamped receipt.
- By mail: Send the signed original to the court address listed on the summons via USPS Certified Mail with return receipt. No fee. Processing is 5โ10 business days from receipt. Keep the green card and the certified mail receipt.
- By fax (limited): A few smaller district courts, like the 88th District Court in Alpena, still accept fax filings under MCR 1.109(G). No fee. Processing is 1โ2 business days. Keep the fax confirmation page.
Attach the DMDC Military Status Report PDF every time, regardless of channel. The DMDC SCRA portal lets you re-download the report by transaction ID for 12 months.
What Happens After You File
Once the clerk dockets DC 104, the judge reviews it together with your MC 07 default request and the court file. If everything matches, the judge signs the default judgment, and you move to the writ of restitution stage under MCR 4.201(L).
If the affidavit says the defendant is in military service, the court must stay the case for at least 90 days under 50 U.S.C. ยง 3932 and may extend the stay further. You cannot get a default judgment until the stay expires and the servicemember still has not appeared.
If the affidavit says you are unable to determine military status, the court will appoint an attorney to represent the absent defendant. The plaintiff usually has to post a bond to cover that attorney’s fees, ranging from $300 to $1,500 depending on the county.
Expect a default hearing date within 14โ30 days of filing. The State Bar of Michigan Real Property Section reports that roughly 70% of properly filed DC 104 affidavits result in same-day or next-day judgment entry.
Mistakes to Avoid When Filling Out the Form
- Wrong revision date. Using an outdated DC 104 (pre-3/19) โ clerk rejects on intake.
- Mismatched case caption. Caption does not match the complaint โ judge denies default for clerical defect.
- Blank paragraph 1. Failing to describe basis of knowledge โ affidavit treated as legally insufficient.
- Two boxes checked in paragraph 2. Contradicts itself โ automatic rejection.
- No DMDC printout attached. Court has no evidentiary backup โ judge orders refiling.
- Pre-signed jurat. Signing before the notary witnesses โ affidavit voided.
- Missing notary seal. Defective jurat under MCR 1.109(D)(3) โ entire filing returned.
- Wrong defendant address. Using forwarding address instead of served address โ exposes judgment to set-aside motion.
- Filing without MC 07. DC 104 alone does not request default โ judge has nothing to sign.
- Ignoring SCRA hit. Proceeding to default despite an active-duty result โ federal misdemeanor under 50 U.S.C. ยง 3931(c), punishable by up to one year in jail.
Do’s and Don’ts
Do’s
- Do download a fresh copy from the SCAO forms library each filing โ revisions roll out without notice.
- Do run the DMDC SCRA search the same week you sign because results older than 30 days look stale to skeptical judges.
- Do file one DC 104 per defendant โ each person gets their own SCRA check.
- Do attach the DMDC printout as a labeled exhibit because the judge wants the evidentiary trail.
- Do keep a notarized copy for your own file because lost court files happen.
- Do verify the notary’s commission is unexpired because expired commissions void the jurat.
Don’ts
- Don’t guess on military status โ guessing is a federal crime when wrong.
- Don’t recycle a DC 104 from an earlier case because each case needs its own fresh affidavit.
- Don’t sign electronically without a MiFILE-approved remote notary.
- Don’t leave the attorney block blank with N/A if you are pro se โ just leave it empty.
- Don’t list the property manager as plaintiff because only the owner of record has standing.
- Don’t use a P.O. box for the court address because venue depends on the physical location.
Pros and Cons of Filing on Your Own vs. With Help
Pros of filing pro se
- Saves attorney fees, which average $250โ$500 just for the affidavit prep in metro Detroit.
- Direct control over timing, so you can run the DMDC search and notarize on your schedule.
- Faster turnaround when you already have the case file because no handoff lag.
- Simple, one-page form means a careful pro se filer can complete it in under 30 minutes.
- Builds familiarity with Michigan summary proceedings for future cases.
Cons of filing pro se
- Federal SCRA exposure is real โ a mistaken not in military box can become a 50 U.S.C. ยง 3931(c) prosecution.
- Notary missteps are the #1 reason pro se DC 104 filings get bounced.
- Pro se filers often forget to pair DC 104 with the MC 07 Default Request, losing weeks.
- No malpractice insurance to lean on if a default gets set aside.
- Judges scrutinize pro se affidavits more closely under MCR 2.603(D).
FAQs
Is DC 104 required for every default judgment in Michigan district court?
Yes. Under MCR 2.603(B)(1) and the federal SCRA, no Michigan court can enter a default judgment against an individual defendant without a sworn military-status affidavit.
Do I write the defendant’s current address or the served address in the right caption block?
No, do not use the current address. Write the address where the defendant was actually served, since the affidavit memorializes service venue, not where the defendant lives today.
Can a property manager sign DC 104 instead of the landlord owner?
Yes, but only if the manager has a written agency authorization on file with the court, and the plaintiff named on the form is still the legal owner of record.
Do I check both boxes in paragraph 2 if I’m not 100% sure?
No. Check only one box. Multiple boxes void the affidavit, and unable to determine exists specifically for uncertain cases.
Is the DMDC SCRA search free?
Yes. Single-record searches at the DMDC SCRA portal are free; bulk searches require a paid account.
Do I need a separate DC 104 for each defendant?
Yes. Each named defendant requires an individualized SCRA inquiry and its own signed affidavit.
Can DC 104 be e-signed in MiFILE?
Yes, but only when paired with a Michigan remote online notarization under MCL 55.261 et seq.; a typed signature alone is not enough.
Is there a filing fee for DC 104?
No. DC 104 has no standalone fee; it is filed within the underlying summary proceedings or civil case file.
Do I need to attach the DMDC printout?
Yes. Although not technically required by the form itself, every Michigan district court expects the DMDC Military Status Report as an exhibit, and most clerks reject affidavits without it.
Can I use a notary commissioned in another state?
Yes, under MCL 55.293, out-of-state notarizations are valid in Michigan if they meet the notary’s home-state requirements.
Does paragraph 1 need to name the DMDC report specifically?
Yes. Naming the DMDC SCRA search as the source of knowledge is the safest path because Gordon v. Pete’s Auto and similar cases demand fact-specific bases.
What happens if I check “is in the military service”?
Yes, the case stays under 50 U.S.C. ยง 3932 โ the court must pause the case for at least 90 days and may appoint counsel for the servicemember.
Can I refile DC 104 if the judge rejects it?
Yes. You can correct and refile as many times as needed, but each refiling restarts the clerk’s processing clock and may delay your writ of restitution by 1โ3 weeks.
Is DC 104 the same form used in small claims cases?
Yes. The same SCAO DC 104 is used in small claims, summary proceedings, land contract forfeiture, and general civil district court cases statewide.
Related reading
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