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Michigan Insurance Company v. National Liability & Fire Insurance

Citation: Not availableDocket: 144792

Court: Michigan Supreme Court; January 17, 2013; Michigan; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

The Michigan Supreme Court reviewed a case involving Michigan Insurance Company and National Liability and Fire Insurance Company, centered on the interpretation of insurance coverage under Michigan's no-fault law. The dispute arose after an adult foster care resident, injured as a pedestrian, sought personal injury protection benefits. The primary legal issue was whether the resident qualified as a 'relative' under the adult foster care corporation's insurance policy. The Supreme Court held that the resident did not qualify, affecting the priority for benefit payments. Under MCL 500.3114(1), the Court determined that Michigan Insurance Company, the insurer of the vehicle owner, was responsible for the benefits, overturning the Court of Appeals' prior judgment. The case was remanded to the Oakland Circuit Court with instructions to grant summary disposition in favor of National Liability and Fire Insurance Company. Justice Cavanagh dissented by preferring the denial of leave to appeal, and Justice Hathaway did not participate in the decision. The ruling clarified the interpretation of 'relative' within insurance policies and reinforced the statutory provisions on priority for benefit payments.

Legal Issues Addressed

Insurance Policy Interpretation under Michigan No-Fault Law

Application: The Michigan Supreme Court determined that an adult foster care resident injured as a pedestrian was not a 'relative' under the adult foster care corporation's insurance policy, impacting the determination of priority for personal injury protection benefits.

Reasoning: The Court determined that an adult foster care resident injured as a pedestrian was not considered a 'relative' of the adult foster care corporation under the insurance policy, thus affecting the priority for payment of personal injury protection benefits.

Priority of Payment for Personal Injury Protection Benefits

Application: The Court held that the insurer of the vehicle owner, Michigan Insurance Company, was responsible for the payment of personal injury protection benefits, as the injured party was not covered under the defendant's policy.

Reasoning: According to MCL 500.3114(1), the insurer of the vehicle owner involved in the accident, Michigan Insurance Company, holds priority for benefits.

Reversal of Court of Appeals Decision

Application: The Michigan Supreme Court reversed the Court of Appeals' decision, concluding that the lower court erred in its interpretation of the insurance coverage for the injured resident.

Reasoning: The Court of Appeals was found to have erred by suggesting that the injured resident could be covered under the defendant’s no-fault automobile insurance policy issued to the adult foster care corporation.