More recently, we focused on the word "recreational," defining that term as " ‘a means of refreshment or diversion[.]’ " Otto v. Inn at Watervale, Inc. , 501 Mich. 1044, 1045, 909 N.W.2d 265 (2018), quoting Merriam-Webster's Collegiate Dictionary (11th ed.) (defining "recreation"). We also rejected the notion that "all of the listed activities involve any particular heightened degree of physical intensity or inherent risk" and held, without adopting any overarching limitations, that beach play—" ‘building sand castles, throwing stones in the water, and splashing around’ "—is covered by the RUA's catchall phrase.
In MCR 7.204(A)(1)(d), the specific words "new trial," "rehearing," and "reconsideration" refer to motions that seek relief from the substance of an order; therefore, the words "other relief from the order or judgment appealed" only encompass other motions that similarly seek relief from the substance of an order. See Otto v Inn at Watervale Inc, 501 Mich. 1044, 1044-1045; 909 N.W.2d 265 (2018) (Under the ejusdem generis canon, when specific words precede general words "the meaning of the general words will ordinarily be presumed to be and construed as restricted by the particular designation and as including only things of the same kind, class, character or nature as those specifically enumerated." (Quotation marks and citation omitted.)
The Michigan Supreme Court has determined that the RUA applies to "beach play," including " ‘building sand castles, throwing stones in the water, and splashing around,’ " because such activities "occurred outdoors and were done for refreshment or diversion, and consequently were recreational." Otto v. Inn At Watervale, Inc. , 501 Mich. 1044, 1044-1045, 909 N.W.2d 265 (2018). The Supreme Court rejected this Court's characterization of the enumerated activities involving "any particular heightened degree of physical intensity or inherent risk."