Michigan Court of Appeals; Docket No. 46981; Published
Judges Bronson, Maher, and O'Brien; Unanimous; Per Curiam
Official Michigan Reporter Citation: 111 Mich App 152; 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 unanimous per curiam Opinion dealing with the one year statute of limitations provisions of §3145 of the Act, the Court of Appeals held that the tolling rule enunciated in Richards v American Fellowship (item number 101) applies to toll the statute only where there is a submission of a specific bill, wage claim or other specific loss, rather than from the date the insured files an application for benefits. Thus, where the plaintiff submitted an application for benefits that was incomplete insofar as specifying a period of wage loss, the plaintiff’s claim was barred by the statute of limitations provisions where suit was not filed within one year of the most recent allowable expense incurred.