Michigan Supreme Court; Docket No. 63019; Published
Opinion by J. Ryan; Unanimous
Official Michigan Reporter Citation: 412 Mich 505; Link to Opinion 
STATUTORY INDEXING:
Entitlement to PIP Benefits: Arising Out of / Causation Requirement [§3105(1)]
Entitlement to PIP Benefits: Motor Vehicle Involvement [§3105(1)]
TOPICAL INDEXING:
Legislative Purpose and Intent
CASE SUMMARY:
In a unanimous Opinion by Justice Ryan, the Supreme Court reversed the Court of Appeals and held that a plaintiff who injured his back while unloading a government owned mail truck and who collected federal workers' compensation benefits, was entitled to maintain an action for no-fault benefits under the no-fault insurance policy on his own private vehicle. The trial court had granted defendant's motion for summary judgment on the ground that the No-Fault Insurance Act does not apply to vehicles owned by the United States, which are not subject to registration with the Secretary of State. The Court of Appeals had affirmed in an unpublished opinion.
Writing for the Court, Justice Ryan held that it is the policy of the No-Fault Insurance Act that persons, not motor vehicles, are insured against loss. The term "motor vehicle" as used in §3105 of the statute making no-fault benefits payable for injury arising out of the use of a motor vehicle as a motor vehicle, does not apply only to a "registered" or an "insured" or a "covered" vehicle. Thus, the insured plaintiff was entitled to collect benefits under his own no-fault insurance policy.
In reaching its decision, the Court of Appeals relied on the earlier case of Shoemaker v National Ben Franklin Insurance Company (item number 43) in which it declared that for an insurer to incur liability under the No-Fault Act there must, at a minimum, be an accident involving a motor vehicle intended to be covered by the statute (i.e., a vehicle that was required to be registered in the State of Michigan). The Supreme Court specifically held that the analysis in Shoemaker was erroneous and, thus, overruled that opinion. The Court stated that the Shoemaker analysis read into the No-Fault Act a more restrictive meaning of the expression "motor vehicle" than was adopted by the legislature. The sections of the No-Fault Statute which the Court of Appeals held must be read together [§3101(1) and §3101(2)] actually speak to separate and distinct subjects. Section 3101(1) speaks only to those categories of persons who are required to carry no-fault coverage and for what duration. On the other hand, §3101(2) sets forth a definition of the term "motor vehicle" as used throughout the statute. It is §3105(1), however, which is the critical provision. This section establishes the circumstances under which personal protection benefits, such as are sought here, are payable. The only requirement of that section is that the motor vehicle involved must merely be used, maintained, operated or owned as a motor vehicle. There is no language whatsoever limiting the definition to a vehicle required to be registered in the State of Michigan or for which no-fault security must be maintained. The Court stated, "We are not left to speculate about whether the legislature intended the expression 'motor vehicle' to mean a covered or registered or insured motor vehicle when it used those words as an expression of art throughout the statute. The meaning of that expression is explicitly set down in the definitional section of the Act, §3101(2). . . . Conspicuously absent is any language limiting 'motor vehicle' to one required to be registered in the state or for which no-fault security must be maintained."
