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Homorogan v Farmers Insurance Exchange and Thorn Apple Valley; (COA-UNP, 3/15/1990; RB #1350)


Michigan Court of Appeals; Docket No. 108604; Unpublished  
Judges Doctoroff, McDonald, and Jansen; Unanimous; Per Curiam  
Official Michigan Reporter Citation:  Not Applicable; Link to Opinion alt   

Coordination with Other Health and Accident Medical Insurance [§3109a]  
Coordination with ERISA Plans [§3109a]

Employee Retirement Income Security Act (ERISA – 29 USC Section 1001, et seq.)   

In this unanimous per curiam Opinion, the Court of Appeals reversed a trial court decision in yet another coordination of benefits claim involving an ERISA health insurance plan. In holding that the trial court erred in failing to find the no-fault insurance coverage provided by Farmers to be secondary to the health insurance policy, the Court of Appeals emphasized that the decision in Northern Group Services (Item No. 1090) was applicable, and had not been repudiated by the recent Supreme Court decision in Liberty Mutual Insurance Group v Iron Workers Health Fund of Eastern Michigan (Item No. 1291).  

Since Iron Workers, supra, involved a total exclusionary clause rather than conflicting coordination clauses, the decision in Northern Group Services, supra, is applicable to the present case, and Farmers Insurance coverage under the No-Fault Act was secondary to the health insurance coverage involved.  

Lansing car accident lawyer Stephen Sinas is the lead editor of the appellate case summaries published on this site regarding the Michigan auto insurance law. To learn more about how Stephen Sinas and how the Sinas Dramis Law Firm can help you if you have been injured in a Michigan auto accident, visit

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