Michigan Office of Administrative Hearings and Rules  
1. Agency Information  
Agency name:  
Licensing and Regulatory Affairs  
Corporations, Securities, & Commercial Licensing  
Name of person completing this form:  
Mackenzie Jones  
Phone number of person completing this form:  
E-mail of person completing this form:  
Name of Department Regulatory Affairs Officer reviewing this form:  
Elizabeth Arasim  
2. Rule Set Information  
MOAHR assigned rule set number:  
2020-131 LR  
Title of proposed rule set:  
Unarmed Combat  
3. Purpose for the proposed rules and background:  
The proposed rules will provide a regulatory structure that would allow the sanctioning of kickboxing  
and Muay Thai events in Michigan. They will improve the reliability and competency of event  
officials and improve the safety and the integrity of “unarmed combat” events in Michigan.  
4. Summary of proposed rules:  
The proposed rules provide a regulatory structure that would allow the sanctioning of kickboxing and  
muay thai events in Michigan. The rules will improve the reliability of event officials and prevent the  
appearance of impropriety. The rules will also set a minimum purse requirement for professional  
unarmed combat sports. Other changes include more flexibility in obtaining a professional contestants  
license, adding an atomweight class for mixed martial arts, and making the mixed martial arts rules  
more consistent with the Association of Boxing Commissions and Combative Sports uniform rules.  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
The Ann Arbor News – November 18, 2021  
The Grand Rapids Press – November 18, 2021  
The Marquette Mining Journal – November 15, 2021  
6. Date of publication of rules and notice of public hearing in Michigan Register:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 2  
7. Date, time, and location of public hearing:  
12/16/2021 01:00 PM at Sun Conference Room , 2407 North Grand River Avenue, Lansing, MI  
8. Provide the link the agency used to post the regulatory impact statement and cost-benefit  
analysis on its website:  
9. List of the name and title of agency representative(s) attending public hearing:  
Mack Jones (LARA)  
Mitchell Page (LARA)  
Benjamin Parker (LARA)  
10. Persons submitting comments of support:  
Wolfgang Mueller  
11. Persons submitting comments of opposition:  
Frank Garza  
12. Persons submitting other comments:  
Collin Rogers  
13. Identify any changes made to the proposed rules based on comments received during the  
public comment period:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 3  
Name &  
Organization public hearing  
Comments made at Written  
Agency Rationale Rule number  
for Rule Change & citation  
and Description changed  
of Change(s)  
Frank Garza  
“Contest official ‘duty  
R 339.204a was  
revised to clarify  
that the duty of  
R 339.204a  
of impartiality’. The  
concept is good but  
the way it is written  
not so much.”  
extends to  
“approved event  
officials” who are  
licensed and  
regulated under  
the Unarmed  
Regulatory Act,  
which include  
timekeepers, and  
referees. The  
agreed that the  
term should be  
modified to  
comply with  
Frank Garza  
“Contest official ‘duty  
of impartiality’. The  
concept is good but  
the way it is written  
not so much.”  
R339.101 was  
revised to remove (b)  
the definition of  
“contest official,”  
from “(1)(b)” in  
favor of listing the  
approved event  
officials within  
R339.204a. The  
agreed that the  
term should be  
modified to  
comply with  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 4  
“With regard to Subsection 6 was R339.203(6)  
other combat added to R339.203  
sports, it is nice to add a uniform  
to see them Federal Boxing ID  
finally addressed card requirement,  
in the proposed which is in line  
rules. I would  
like to see the  
with the ABC  
Model Rules  
which the  
card requirements Commission  
for professional wishes to adhere  
kickboxing and to on this change.  
muay thai  
specified in the  
rules, as I did not  
see specific  
addressing that  
aspect of the  
“Rule 201, Rule The rule was  
223b(2), Rule  
edited so that the  
language”) , Rule was replaced with  
223c(5), and Rule “accidental” to be  
226b(a), all  
derive from  
ABC’s model  
consistent with the  
other existing  
rules mentioned in  
rules. It does not the written  
appear that these statement (Rule  
rules are  
339.223c) as well  
as current practice.  
consistent with  
current practice  
and regulations  
relating to other  
unarmed combat  
sports in  
“…Rule 223b(2),  
Rule 339.223c  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 5  
“…Rule 226b(a), The rule was  
all derive from  
ABC’s model  
edited so that the  
types of decisions  
rules. It does not were modified to  
appear that these be uniform across  
rules are  
consistent with  
all sports, and in  
226b(a) added the  
current practice language for  
and regulations  
“Unanimous” and  
relating to other “Split” decisions  
unarmed combat as 226b(a)(i)(ii)  
sports in  
and (iii). The  
agreed that the  
decisions in this  
rule should follow  
current practice  
and align with the  
other sports, which  
is a slight  
departure from the  
ABC model rules.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 6  
Collin Rogers  
“The revision of The rule was  
R339.101 Rule  
101 (L) states  
""Muay thai"  
edited, and the  
rule number  
changed, to add in  
means a form of “elbow” to the  
boxing in which definition of  
blows are  
“Muay thai” to  
delivered with the read “’Muay thai’  
hand, any part of means a form of  
the leg below the boxing in which  
hip, including the blows are  
foot, and  
clinching. Does hand, elbow, any  
this infer that part of the leg  
delivered with the  
there will be no below the hip,  
elbows allowed including the foot,  
as a weapon in  
and clinching.”  
any occurance of Instead of being  
Muay Thai in the listed as R339.101  
state of Michigan, (l), the definition  
be it pro or  
amateur? Elbow listed as R339.101  
pads are an (k). The  
additional option Commission  
was changed to be  
that could  
become a  
agreed that this  
was in line with  
current practice.  
equipment under  
R339.246b Rule  
246b as Muay  
Thai after all is  
"the art of eight  
limbs" (legs,  
knees, hands,  
Collin Rogers  
In 232b(1)(c), the R339.232b(1)  
“In Rule 232b (1) language was  
it is stated "A changed to read  
referee of a muay “Direct attacks to (u)  
thai contest may the back of the  
penalize a muay knee.” In (u), the  
thai contestant by language was  
deducting points changed to read  
from a round for “Illegal tripping or  
any of the  
sweeping the back  
following fouls: of an instep  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 7  
"(c) Direct  
attacks to the  
supporting leg of  
an opponent.” The  
knee." Does this Commission  
blanket all attacks agreed that this  
that may contact was more in line  
the knee I.E. low- with current  
kicks to the calf practice.  
or thigh area,  
front-kicks to the  
thigh or hip, etc.?  
As well as "(i)  
throwing, or  
wrestling an  
opponent when  
pushing in a legal  
clinch." Does this  
mean a contestant  
may not, if the  
presents itself,  
shove an  
opponent out of  
the clinch and  
resume attacking?  
This carries into  
my next question  
of the same  
ruleset under "(u)  
Tripping or  
sweeping an  
opponent." being  
listed as a foul. In  
Muay Thai  
fighting, tripping  
and/or sweeping  
an opponent is a  
technique very  
often utilized to  
show technical  
precision and  
timing over your  
opponent. I see  
no reason why  
these techniques  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 8  
should be listed  
as fouls under a  
Muay Thai  
ruleset in  
Michigan if the  
wishes of the  
commission are  
to display the true  
nature of such a  
beautiful martial  
art and preserve  
the integrity of  
the sport.”  
Collin Rogers  
Added the  
“In most other  
language “if  
states we've had contestants agree  
fighters compete before a contest to  
in, the headgear wear protective  
was an optional headgear and shin  
selection, based and instep  
on the bout  
protectors” to  
adhere to current  
preference. If one practice of the  
preferred that  
headgear be  
worn, both would  
be required. If  
both agreed on no  
headgear, it was  
allowed. The  
same could be  
said for  
shinguards in  
some states.”  
14.Date report completed:  
MCL 24.242 and 24.245