Entitlement to PIP Benefits – Michigan
Steanhouse v. Michigan Auto. Ins. Placement
Facility
--- N.W.3d ---, 2024 WL 1588626 (Mich. App. April 11, 2024)
The Michigan Court of Appeals reaffirmed its prior holding that a claimant who resides in Michigan is not entitled to Personal Protection Insurance (PIP) benefits through the Michigan Assigned Claims Plan (MACP) for injuries arising from an out-of-state car accident. In so holding, the appellate court reversed the judgment of the trial court and remanded the case to that court for further proceedings.
In 2019, plaintiff Markise Steanhouse was injured in a motor vehicle accident in Ohio. Steanhouse applied for PIP benefits through the MACP, but he was denied coverage. Steanhouse filed suit, and defendants, Michigan Automobile Insurance Placement Facility and MACP, filed a motion for summary disposition, arguing that in order to claim PIP benefits, the accident giving rise to the claim must have occurred in the state of Michigan.
As support, the defendants relied on MCL 500.3172, which expressly stated that “[a] person entitled to claim because of accidental bodily injury arising out of the ownership, operation, maintenance, or use of a motor vehicle as a motor vehicle in this state may claim [PIP] benefits through the assigned claims plan.” (Emphasis added). The trial court denied the motion for summary disposition, holding that this provision of the statute conflicted with another provision of the No-Fault act, MCL 500.3114. This provision provided, in pertinent part, that PIP benefits were payable to “an occupant of a vehicle involved in the accident, if the occupant was a resident of this state.” Because Steanhouse was a resident of Michigan, the trial court held that he could not be deprived of coverage through the MACP.
On appeal, the Michigan Court of Appeals concluded that the statutes did not conflict and reversed the trial court. The Michigan Supreme Court remanded the case back to the intermediate court with instructions to address the impact of MCL 500.3114 on whether Steanhouse was eligible to claim benefits through the MACP. The Michigan Court of Appeals reaffirmed its holding. The appellate court declined to accept Steanhouse's argument that MCL 500.3172 had no application to out-of-state accidents or that the statutes conflicted. As to the latter argument, the appellate court applied the statutory canon that when two statutes conflict, courts must apply the more specific one. Because MCL 500.3172 was more specific, the appellate court applied it to preclude coverage for Steanhouse under the MACP.
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