Michigan Court of Appeals; Docket No. 44335; Published
Judges Danhof, R. B. Burns, and MacKenzie; Unanimous; Per Curiam
Official Michigan Reporter Citation: 97 Mich App 204; Link to Opinion 
STATUTORY INDEXING:
One-Year Notice Rule Limitation [§3145(1)]
Applicability of Limitations Period to Claims by Insurers Against Other Insurers [§3145]
TOPICAL INDEXING:
No-Fault Insurer Claims for Reimbursement
CASE SUMMARY:
In a unanimous per curiam Opinion, the Court of Appeals held that where a no-fault insurer pays no-fault benefits to an insured person where its liability to pay is arguably secondary to that of another insurer, the paying insurer becomes subrogated to the rights of the injured person and may file a separate action for subrogation against the other insurance company. However, such a subrogation action is governed by the one year statute of limitation provisions set forth in §3145(1) of the Act Consequently, the plaintiff insurance company cannot avoid the provisions of this statute of limitation by terming its subrogation action as "an action in quasi contract." Doing so would thwart the legislative intent of the Act to give quick notice of claims and promote prompt payment.