Michigan Court of Appeals; Docket No. 243614; Unpublished
Judges Cooper, O’Connell, and Fort Hood; unanimous; per curiam
Official Michigan Reporter Citation: Not applicable, Link to Opinion 
STATUTORY INDEXING:
Not applicable
TOPICAL INDEXING:
Uninsured Motorist Benefits: Notice and Statute of Limitations for Uninsured Motorist Coverage
CASE SUMMARY:
In this unanimous unpublished per curiam opinion, the Court of Appeals held that the 24 hour notice requirement contained in the “hit-and-run” uninsured motorist provisions of State Farm’s policy did not require written notice to the police within 24 hours. An oral notice was sufficient under the policy. The policy required that, as a condition for qualifying for uninsured motorist benefits under the hit-and-run language of the policy, that the insured must “report a hit-and-run accident to the police within 24 hours.” The court held that the noun “report” is defined as a “formal oral or written presentation of the facts.” Further, the verb report is defined as “to give a formal account or statement.” Under these definitions, the policy requires only that the plaintiff report the accident to the police. A person may report something orally as well as in writing. Therefore, the trial court requirement of written notice was in error and reversed.