How to Complete and File Michigan Form PC 564: Proof of Service

Michigan Form PC 564 is the Proof of Service you file in probate court after you have delivered a petition, notice, account, or other document to every interested person in the case. You complete it once service is done, sign it under penalty of perjury, and submit it to the probate court so the judge has a written record that notice was given.¹ Without the form in the file, the court will generally refuse to hold the hearing or act on the petition.

When PC 564 Has to Be Filed

Any time you serve a petition, notice of hearing, account, or report on an interested person in a Michigan probate matter, a PC 564 has to follow. Michigan Court Rule 5.104 requires that accounts and reports served on interested persons include a proof of service, and the court will not accept those filings without one.² The form is used across probate case types: decedent estates, guardianships, conservatorships, and protective proceedings all trigger the same requirement.

One alternative worth knowing about before you serve anyone. If an interested person is willing to skip formal notice, they can sign Form PC 561 (Waiver/Consent) instead, confirming they received a copy of the petition and waiving notice of the hearing.³ PC 561 cannot be used for waivers tied to the appointment of a personal representative under MCL 700.3310, so a PC 564 is still required in that situation.

Who Is Allowed to Serve the Documents

You cannot serve the papers yourself if you are the petitioner or any other party in the case. Under Michigan Court Rule 2.103, the person who delivers or mails the documents must be a legally competent adult who is not a party and is not an officer of a corporate party.⁴ A friend, an uninvolved relative, a paralegal, or a professional process server can do it. Whoever handles service is the person whose information goes on the PC 564 and who signs the declaration at the bottom.

Service Methods and the Deadlines You Have to Meet

Michigan Court Rule 5.105 recognizes several ways to deliver probate documents, and each one has its own deadline measured backward from the hearing date. PC 564 asks you to identify which method you used, so pick the right one before you serve.

Personal Service

Personal service on an individual can be done three ways: handing the papers directly to the person, leaving them at the person’s usual residence with someone of suitable age and discretion who lives there, or sending them by registered or certified mail with return receipt requested and delivery restricted to the addressee. For the mail option, service is not complete until the individual actually receives the document. Personal service must be completed at least seven days before the scheduled hearing.²

First-Class Mail

For interested parties who do not require personal service, you can mail a copy in a sealed envelope with first-class postage, addressed to the person and deposited in the United States mail. Service by mail is considered complete at the time of mailing; you do not have to prove the recipient opened it. Mailed documents must be sent at least 14 days before the hearing.²

Electronic Service

Parties and interested persons can agree to service by email under MCR 2.107(C)(4), and electronic service through the MiFILE system is permitted under MCR 1.109(G)(6)(a). Electronic service must be completed at least seven days before the hearing, the same deadline as personal service.

Service by Publication

When you cannot find an interested person’s address, you can serve by publication, but only after filing a verified declaration with the court explaining that a diligent search failed. Publication then follows the manner required by MCR 5.106.⁵ If that person’s address later becomes known during the case, you serve them normally from then on.

Filling Out the Form

You can download PC 564 from the Michigan Courts website at courts.michigan.gov or pick up a paper copy at your local probate court clerk’s office.¹ If the case is in a circuit court family division rather than probate court, enter the court name and county in the upper left corner instead of the probate court fields.

Case Caption

Copy the case name and file number from the first page of the document you served. These must match the existing court record exactly. A mismatched case number is one of the easiest ways to get the filing rejected at the clerk’s window.²

Section 1: Papers Served

Write the title of each document you served, taken from the top of the first page of that document. “Petition for Probate and Appointment of Personal Representative” or “Notice of Hearing” are typical entries. List every document included in the service, not just the main petition.²

Section 2: Service by Mail

If you served by mail, check the box for first-class, registered, or certified mail and list the full name and address of each person served along with the date of mailing.¹ For registered or certified mail, attach the return receipt. If any envelope comes back undeliverable, do not assume the person was notified. Document the failed delivery and ask the court about serving that individual by publication or another method.

Section 3: Personal Service

If you served in person, check the personal service box and enter the name and address of each person served along with the date and time service occurred.² The time is not a formality. The court uses it to verify the seven-day cushion before the hearing.

Signature

Sign and date the form at the bottom. The printed declaration above the signature line reads, “I declare under the penalties of perjury that this proof of service has been examined by me and that its contents are true to the best of my information, knowledge, and belief.”¹ No notary is required; the perjury declaration takes the place of notarization. Filing a PC 564 with false information exposes you to criminal perjury penalties, so check every detail before you sign.

Filing the Signed Form

Submit the signed form to the probate court handling the case. Michigan Court Rule 1.109(G) established MiFILE as the statewide electronic filing system, and many courts now require electronic filing through it.⁶ To e-file, upload a scanned or digitally completed version of the form through the MiFILE portal. Filing fees are paid at submission unless you qualify for an exemption or fee waiver under MCR 2.002. Fee amounts vary by court, so confirm the cost with your local probate clerk or through MiFILE.

If you are not required to use MiFILE, which depends on the county and whether you are self-represented, you can deliver the original form to the probate court clerk’s window or mail it to the court. The clerk reviews the submission to confirm the case number and caption match the record. Once accepted, you should receive a file-stamped copy. Keep it. If anyone later claims they were never notified, that stamped proof of service is your defense.

Mistakes That Delay the Hearing

The most common problem is serving the right documents to the wrong list of people, or to the right people at outdated addresses. Confirm current addresses for every interested person before you serve anything. Probate courts read notification rules strictly, and a single missed party can force the judge to adjourn.

Missing the deadline. Mail requires 14 days before the hearing; personal and electronic service require 7. Late service usually means postponement.
Wrong method for the person. Some parties, particularly the subject of a guardianship or conservatorship petition, must be served personally rather than by mail. Check the rule for your case type before you choose.
Blank fields. Leaving the date, time, or address off gives the court no way to verify compliance. Fill in every field for every person served.
Missing return receipts. If you used registered or certified mail, the return receipt has to be attached. Without it, the form does not actually prove delivery.
Serving everyone and then not filing PC 564 at all. The judge cannot take your word for it. The signed form has to be in the case file before the hearing moves forward.

When service fails, address it early. File the returned envelope with the court and ask whether publication or another method is appropriate for that individual. Judges are far more receptive to a petitioner who documents a good-faith effort than to one who quietly skips a hard-to-find party.

1
Michigan Courts. Michigan Court Form PC 564 – Proof of Service
2
Leelanau County. Instructions for Completing Proof of Service (PC 564)
3
Michigan Courts. Waiver/Consent
4
Michigan Courts. Service of Process
5
CourtRules.net. Rule 5.105 Manner and Method of Service
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Michigan Courts. Michigan Court Rules on E-Filing and E-Service