Michigan Court of Appeals; Docket No. 96649; Unpublished
Judges Kelley, Sullivan, and Shamo; Unanimous; Per Curiam
Official Michigan Reporter Citation: Not Applicable; Link to Opinion 
STATUTORY INDEXING:
Entitlement to PIP Benefits: Arising Out of / Causation Requirement [§3105(1)]
TOPICAL INDEXING:
Not Applicable
CASE SUMMARY:
In this unanimous per curiam Opinion, the Court of Appeals determined that plaintiff’s son was entitled to no-fault benefits as a result of injuries suffered while plaintiff was in the course of cleaning the inside of a pickup truck/camper insured by defendant
Plaintiff was in the course of cleaning the inside of the camper and had heated hot water for this purpose on a cook stove inside the camper. During this process, the water was somehow upset and fell onto plaintiff’s child. The lower court found that the injuries sustained by the child were the result of "maintenance" of a motor.vehicle within the meaning of the no-fault statute.
Auto Club argued on appeal that the injuries did not arise out of the ownership, operation, maintenance or use of a motor vehicle within the meaning of §3105(1). Defendant argued that the motor vehicle was merely the site of an injury that could have occurred anywhere there was a stove or a pan of hot water. Citing the case of Coole v Michigan Mutual (Item No. 775), the Court noted that in that case the normal use of a camper was determined to include the operation of a gas fueled heater or furnace. Here, the Court found that it did not require any great leap of logic to conclude that the normal use of the Griffin camper as a motor vehicle included the use of its permanently attached cook stove. The Court further held that the cleaning of the passenger compartment of a camper should be considered maintenance within the broad definition of that word set forth in §3105(1), regardless if the method chosen to do so was "unorthodox."
