Michigan Court of Appeals; Docket No. 66236; Unpublished
Judges Walsh, T. M. Burns, and Lambros; Unanimous; Per Curiam
Official Michigan Reporter Citation: Not Applicable; Link to Opinion 
STATUTORY INDEXING:
One-Year Back Rule Limitation [§3145(1)]
Tolling of Limitations Upon Submission of Claim [§3145]
TOPICAL INDEXING:
Not Applicable
CASE SUMMARY:
In this short unanimous per curiam Opinion, the Court of Appeals reversed entry of accelerated judgment for defendant under the no-fault statute's one-year back rule contained in §3145(1). The Court of Appeals adopted the tolling rule set forth in Richards v American Fellowship (item number 101). In so holding the Court stated, "We are persuaded, however, that the one-year limitation on commencing suit and recovery of expenses was tolled in this case from the date defendant was notified of plaintiff’s additional period of wage loss until defendant formally denied plaintiff’s claim for additional wage loss benefits in November, 1981."