Michigan Court of Appeals; Docket No. 203260; Published
Judges Gribbs, Griffin, and Wilder; Unanimous; Opinion by Griffin
Official Michigan Reporter Citation: 238 Mich App 673; Link to Opinion 
STATUTORY INDEXING:
Entitlement to No-Fault PIP Benefits: Bodily Injury Requirement [§3105(1)]
Aggravation of Preexisting Conditions [§3105(1)]
TOPICAL INDEXING:
Not Applicable
CASE SUMMARY:
In this unanimous published Opinion by Judge Griffin, the Court of Appeals held that there was no abuse of discretion by the trial court in determining, pursuant to a Davis-Frye hearing, that there was a causal relationship between stress and Graves' disease. Therefore, plaintiff was entitled to recover no-fault benefits pursuant to section 3105(1) of the act, based upon his claim that the stress of the automobile accident had precipitated development of his Graves' disease.
Plaintiff Alexis Anton was involved in a motor vehicle accident, and shortly thereafter, began to experience symptoms of what was ultimately diagnosed as Graves' disease. Prior to trial, State Farm requested that any expert testimony by plaintiffs treating physician to the effect that the automobile accident had precipitated plaintiffs Graves' disease should be excluded because plaintiffs theory of medical causation had not achieved general scientific acceptance or been independently validated as required by the Davis-Frye rule. The trial court conducted a Davis-Frye inquiry, reviewing the deposition testimony of plaintiffs treating physician, an endocrinologist, and defendant's expert. Upon reviewing the evidence by way of deposition, the trial court determined that there was sufficient evidence on the record so as to warrant admission of plaintiff’s physician's testimony on the medical causation issue.
The Court of Appeals held that, absent an abuse of discretion, the qualification of an expert witness and the admissibility of testimony will not be reversed on appeal. In reliance upon MRE 702, the court noted that it must be determined whether the proposed testimony is derived from "recognized scientific knowledge." Based upon the evidence, the Court of Appeals held that the trial court did not abuse its discretion in allowing the testimony, as both experts had testified that the medical community recognizes a causal link between stress and Graves' disease. The court stated, "The subject of the scientific testimony need not be known to a 100% certainty, as long as the basic principles employed by an expert to reach a conclusion are sound and create a trustworthy foundation for the conclusion reached." Therefore, the court held that there was sufficient basis to allow the testimony which the jury ultimately determined was sufficient to establish that plaintiffs Graves' disease arose out of the ownership, operation, use, or maintenance of a motor vehicle as required by section 3105(1) of the No-Fault Act.
The court also upheld the jury verdict awards for wage loss and medical expenses, finding that there was ample evidence in the record to support the verdict
