58th District Court; Docket No. G-93-367-GC; Docket No. 187617;
Honorable Richard J. Kloote; Unpublished
Official Michigan Reporter Citation: Not Applicable; Link to Opinion 
STATUTORY INDEXING:
Allowable Expenses: Reasonable Necessity Requirement [§3107(1)(a)]
Requirement That Benefits Were Unreasonably Delayed or Denied [§3148(1)]
TOPICAL INDEXING:
Not Applicable
CASE SUMMARY:
This case for no-fault first party coverage involved a dispute over chiropractic charges. The plaintiff was injured in an automobile accident which occurred on June 12,1992, and received chiropractic treatment for her injuries. The defendant insurance company had the chiropractic charges audited by a company known as "Review Works" and denied coverage for a substantial portion of the charges. The case was submitted to trial, upon the conclusion of which, the jury entered a verdict in plaintiffs favor, finding that the chiropractic bills in the amount of $1,962.38 were reasonably necessary. It appears that the amount of charges was not contested as being unreasonable.
The trial court found that the insurance company's refusal to provide coverage to be unreasonable, and accordingly, awarded the sum of $7,163.50 in attorney fees under §3148(1) of the No-Fault Act. The attorney fee award was based upon an hourly rate of $150 per hour.
