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Steanhouse v Mich Auto Ins Placement Facility, et al (COA – PUB 12/22/2022; RB #4514)   

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Michigan Court of Appeals; Docket #359576; Published  
Judges Cavanagh, Kelly, and Garrett; Authored by Judge Garrett 
Official Michigan Reporter Citation: Forthcoming; Link to Opinion


STATUTORY INDEXING: 
Entitlement to Benefits for Out of State Accidents [§3111]
When Claimants Can Receive PIP Benefits Through the Assigned Claims Facility [§3172]

TOPICAL INDEXING: 
Not Applicable


SUMMARY: 
In this unanimous, published decision authored by Judge Garrett, the Court of Appeals reversed the trial court’s denial of Defendant Michigan Automobile Insurance Placement Facility’s (“MAIPF”) motion for summary disposition, in which it sought dismissal of Plaintiff Markise Steanhouse’s action against it.  Steanhouse was injured in a motor vehicle accident in Ohio and sought no-fault PIP benefits through the MAIPF, but the Court of Appeals held that Steanhouse was ineligible for PIP benefits through the MAIPF based on the plain language of MCL 500.3172, or because his accident did not occur in Michigan.  In so holding, the Court rejected Steanhouse’s two-fold argument that (1) his eligibility for PIP benefits relative to the accident was established by MCL 500.3111, and (2) because MCL 500.3172 conflicts with MCL 500.3111, the former could not be interpreted so as to deprive him of his right to benefits.

Markise Steanhouse was injured in a motor vehicle accident in Ohio, and subsequently sought no-fault PIP benefits from the MAIPF.  The MAIPF declined to assign his claim because his accident occurred out of state, and in Steanhouse’s resultant action against the MAIPF, the MAIPF moved for summary disposition.  Steanhouse argued, in response, that his entitlement to PIP benefits relative to the accident was established by MCL 500.3111, because he was “(1) was involved in an accident which occurred in the United States, (2) was an occupant of a vehicle and was injured, and (3) was a resident of the state of Michigan.”  Furthermore, Steanhouse argued that MCL 500.3172 could not be interpreted as depriving him of his eligibility for PIP benefits which was clearly established by MCL 500.3111.  The Court of Appeals agreed with Steanhouse and denied the MAIPF’s motion, stating, ‘MCL 500.3172 conflicts with MCL 500.3111 and otherwise cannot be interpreted as depriving assigned coverage to Michigan residents simply because they were injured in accidents in other states.”

The Court of Appeals reversed the trial court’s summary disposition, holding (1) that Steanhouse’s eligibility for PIP benefits through the MAIPF was governed by MCL 500.3172, not MCL 500.3111, and (2) that Steanhouse was ineligible for PIP benefits through the MAIPF because his accident occurred out of state.  The Court noted, preliminarily, that ‘provisions of a statute that could be in conflict must, if possible, be read harmoniously.’  Then, in attempting to harmonize the two statutes, the Court determined that “MCL 500.3111 generally informs claimants of the circumstances under which PIP benefits are payable, while MCL 500.3172 sets forth the eligibility criteria for claimants to seek PIP benefits through the MACP when no insurance is readily applicable and the accident occurs in Michigan.”

To further support its determination, the Court referenced a second rule of statutory construction, that ‘if two provisions in a statute conflict [and cannot be read in harmony], we must apply the more specific one.’  In this case, MCL 500.3172, was the more specific statute and thus, even if a true conflict existed, MCL 500.3172 would apply.

“Put differently, MCL 500.3111 generally informs claimants of the circumstances under which PIP benefits are payable, while MCL 500.3172 sets forth the eligibility criteria for claimants to seek PIP benefits through the MACP when no insurance is readily applicable and the accident occurs in Michigan. These provisions apply in different settings, as the Legislature created a statutory scheme specific to claims brought under the MACP. See MCL 500.3114(6) (stating a person shall claim PIP benefits ‘under the assigned claims plan under [MCL 500.3171 to MCL 500.3175]’ when no higher-priority sources of PIP coverage are available). And nothing in MCL 500.3111 references the MAIPF or the MACP. Importing statutory language relevant to claims brought under a no-fault policy to govern claims brought through the MACP is inconsistent with the plain language of the statute. Because Steanhouse seeks PIP benefits through the MACP, he must meet the criteria of MCL 500.3172, not MCL 500.3111, to be eligible. Therefore, the trial court erred when it denied defendants’ motion for summary disposition because the statutes can be read harmoniously to effectuate their separate purposes. 

Furthermore, even assuming MCL 500.3172 and MCL 500.3111 cannot be read in harmony, MCL 500.3172 is the more specific statute and should control. See In re Huntington Estate, 339 Mich App 8, 22; 981 NW2d 72 (2021) (‘[I]f two provisions in a statute conflict, we must apply the more specific one.’). Although MCL 500.3111 generally provides PIP benefits for claimants when an accident occurs outside of Michigan, it does not dictate the terms by which claimants may receive PIP benefits through the MACP and MAIPF. Rather, MCL 500.3172 defines who is eligible to receive PIP benefits through the MACP and specifically states that claimants whose accidents occur in Michigan are eligible. Because MCL 500.3172 applies to the MACP and MAIPF, and Steanhouse is seeking PIP benefits through the MACP and MAIPF, applying MCL 500.3111 is improper.” 


Michigan auto accident attorney 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 SinasDramis.com.

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