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Citizens Insurance Company of America v MidMichigan Health ConnectCare Network Plan; (6TH Cir.-PUB, 6/1/2006, RB #2903)


United States Court of Appeals for the Sixth Circuit; Docket #05-1237; Published
Judges Moore, McKeague, and Polster; 2-1 (Judge Moore dissenting)
Official Reporter Citation: Forthcoming, Link to Opinion courthouse graphic

Coordination with ERISA Plans [3109a]

Not applicable

In this 2-1 published opinion, the Sixth Circuit Court of Appeals determined that even though a coordinated no-fault policy did not specifically exclude medical expenses covered by a medical or health benefits plan, where such a plan did not exclude coverage for medical expenses arising out of a motor vehicle accident, that plan is first in priority for payment of medical expenses.

The injured person in this case, Jacqueline Bradshaw, had a coordinated no-fault policy with plaintiff Citizens Insurance Company. Plaintiff was also covered by an ERISA employee benefit plan through defendant MidMichigan Health ConnectCare. Although defendant’s plan did not specifically exclude payment for injuries otherwise covered by no-fault insurance, the district court determined that Citizens was first in priority for payment of Bradshaw’s benefits. In an opinion by Judge McKeague, the court reversed, finding that because the benefit plan did not exclude payment for medical coverage otherwise payable under a no-fault policy, and the Citizens policy excluded payment of medical benefits covered by other coverage plans, including a benefit plan such as defendant’s, defendant’s plan was first in priority. In this regard, the court stated:

[T]he intent underlying the Exclusions provision clearly militates in favor of Citizens interpretation, we find that Citizens properly excluded payment of medical benefits for a series of plans, including a ‘benefit plan.’ MidMichigan is such a plan. Because MidMichigan’s plan was in full force at the time of Bradshaw’s injury, and the plan did not expressly disavow coverage for medical benefits otherwise payable under a no-fault policy, we find that MidMichigan is first in priority for payment of Bradshaw’s claims.”

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