Michigan Court of Appeals; Docket #232517; Unpublished
Judges White, Neff and Jansen; unanimous; per curiam
Official Michigan Reporter Citation: Not Applicable, Link to Opinion 
STATUTORY INDEXING:
Allowable Expenses for Room and Board [3107(1)(a)]
TOPICAL INDEXING:
Not applicable
CASE SUMMARY:
In this unanimous unpublished per curiam opinion, the Court of Appeals held that room and board expenses, including food, are allowable expenses under section 3107(1)(a) of the No-Fault Act.
Douglas Griffith was severely injured in a motor vehicle accident, rendering him totally disabled. He required constant monitoring, care and assistance with every aspect of life. He spent the first 15 months following the accident receiving in-patient treatment in hospitals and rehabilitation facilities. For two years thereafter, he lived in a modified apartment and received continuous care. Subsequent to that, he returned to his home where his wife and other attendants provided the care he requires. State Farm disputed its obligation to pay for food for Douglas, reasoning that a person must consume food regardless of whether he is disabled and regardless of where he resides, and maintaining that once Douglas returned home, his food expenses were no longer incurred as a result of his injuries.
In affirming the trial court decision requiring payment for food expenses as an allowable expense under the No-Fault Act, the Court of Appeals held that this issue was controlled by Reed v Citizens Insurance Company, 198 Mich App 443; 499 NW2d 22 (1993). Citing from Reed, the court upheld the trial court ruling that food expense was an allowable expense under the No-Fault Act:
“In Reed, this Court held that where a person injured in a motor vehicle accident is unable to care for himself or herself and would be institutionalized if a family member were unwilling to provide home care, a no-fault carrier liable for the cost of maintenance in an institution is liable for the cost of maintenance, including room and board, in the home.”
Therefore, the court held that the cost of Griffith’s food is an allowable expense under 3107(1)(a).
