48th Judicial District Court; Docket No. 853-0221 -CK;
Judge Edward Sosnick;
Official Michigan Reporter Citation: _____; Link to Opinion 
STATUTORY INDEXING:
Allowable Expenses for Rehabilitation [§3107(1)(a)]
Allowable Expenses: Reasonable Necessity Requirement [§3107(1)(a)]
TOPICAL INDEXING:
Not Applicable
CASE SUMMARY:
In this case of first impression, District Judge Sosnick held that plaintiff was entitled to recovery of allowable expenses for the services of a Christian Science practitioner engaged for plaintiff husband's rehabilitation. Defendant had moved for summary disposition claiming that, as a matter of law, Christian Science treatment is not an "allowable" expense within the meaning of the No-Fault Act, and secondly, that the expense is not "reasonably necessary" within the meaning of the same statute.
Plaintiffs were involved in a jeep rollover accident resulting in a closed head injury to Mr. Stephenson. Mr. Stephenson was admitted to the hospital on January 28, 1984, and discharged on February 17, 1984. While in the hospital, Mr. Stephenson was comatose for a period of time. His wife engaged a Christian Science practitioner to assist in the rehabilitation of her husband while in the hospital. Pursuant to the Christian Science faith, all treatment for the patient was done through prayer. Plaintiffs claimed $1,775 for the services rendered by the Christian Science practitioner. Citing the test adopted by the Court of Appeals in Manley v DAIIE (Item No. 601), the district court held that the services are covered by the No-Fault Act in that Mrs. Stephenson would not have engaged the services of a Christian Science healer if her husband had not been rendered in a comatose state as a result of the automobile accident. Thus, the service was "not as necessary for an uninjured person as it was for an injured person." Therefore, as a matter of law, the District Court held that such services fall within the meaning of "allowable expenses" as defined by the statute.
