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Steanhouse v. Mich. Auto. Ins. Placement Facility
Wayne Circuit Court LC No. 20-014854-NF
Before: CAVANAGH, P.J., and K. F. KELLY and GARRETT, JJ.
ON REMAND
This case involves the interplay between various provisions of Michigan's no-fault act, MCL 500.3101 et seq. We are asked to determine whether plaintiff, Markise Steanhouse is eligible to claim personal protection insurance (PIP) benefits through the Michigan Assigned Claims Plan (MACP) for injuries arising from an out-of-state car accident.
In Steanhouse v MAIPF, Mich. App,; NW3d (Docket No 359576); slip op at 6 (Steanhouse I), we held that "MCL 500.3172(1) requires a claimant seeking benefits through the MACP to show that the accident giving rise to the claim occurred in Michigan." Therefore, because the accident at issue did not occur in Michigan, Steanhouse was not entitled to PIP benefits, and defendants-the MACP and its administrator, the Michigan Automobile Insurance Placement Facility (MAIPF)-were entitled to summary disposition. Id. The Supreme Court vacated our opinion and remanded for reconsideration to "address the impact, if any, of MCL 500.3114 on whether the plaintiff is eligible to claim benefits through the [MACP]." Steanhouse v MAIPF, 512 Mich. 928, 928 (2023) (Steanhouse II). We conclude that MCL 500.3114 does not impact Steanhouse's eligibility, so we again reverse.
In the prior appeal, we summarized the facts underlying this litigation:
In November 2019, Steanhouse was injured in a motor vehicle accident in Ohio. Steanhouse applied for PIP benefits through the MACP in September 2020. Alleging that defendants unlawfully refused to assign an insurer to pay him PIP benefits, Steanhouse brought suit. Defendants moved for summary disposition, arguing that in order to claim PIP benefits through the MACP under MCL 500.3172(1), the accident giving rise to the claim must have occurred in the state of Michigan. Defendants reasoned, therefore, that Steanhouse was not entitled to receive PIP benefits through the MACP because there was no genuine issue of material fact that the accident occurred in Ohio.
Steanhouse responded, disputing defendants' interpretation of MCL 500.3172(1). Steanhouse also asserted that under MCL 500.3111, he was entitled to PIP benefits because he (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. He noted further that MCL 500.3113, a provision detailing who is not entitled to PIP benefits, made no mention of out-of-state accidents involving in-state residents.
Defendants replied, arguing MCL 500.3172 only applied to in-state accidents and contending that MCL 500.3111 did not control the case. In defendants' view, MCL 500.3111 contemplated insurance policies in effect for named insureds, spouses, resident relatives, or occupants of insured vehicles, whereas MCL 500.3172 specifically applied to the MACP and the MAIPF. Thus, MCL 500.3172, not MCL 500.3111, applied here.
The trial court denied defendants' motion for summary disposition, stating that "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." Defendants moved for reconsideration, arguing that the trial court erred when it ruled MCL 500.3172 and MCL 500.3111 conflict, and that even if the statutes conflicted, MCL 500.3172 should apply because it was the more specific statute. The trial court denied reconsideration and explained that it "does not believe that otherwise uninsured Michigan residents lose their right to coverage through MAIPF when they are injured in an accident that occurs in another state." Defendants filed an application for leave to appeal the trial court's order denying summary disposition, arguing again that Steanhouse was ineligible to receive PIP benefits through the MACP under MCL 500.3172(1). We granted the application to resolve this question of statutory interpretation under the no-fault act. [Steanhouse I, Mich.App. at; slip op at 2.]
In Steanhouse I, id. at 3-4, we held that, under the plain language of MCL 500.3172(1), a claimant is not eligible for PIP benefits through the MACP when the underlying accident occurs outside of Michigan. Although arguably in tension with MCL 500.3111, we concluded that MCL 500.3172(1) controlled the resolution of the case. Id. at 4-5. Because it is undisputed that Steanhouse's injuries arose from an out-of-state car accident, we reversed the trial court's order denying defendants' motion for summary disposition and concluded that Steanhouse was not entitled to benefits through the MACP. Id. at 6.
Although Steanhouse filed no brief in this Court before our prior decision, he sought leave to appeal in the Supreme Court. Steanhouse raised several new arguments, including that MCL 500.3114(4) provided him with coverage. As noted, the Supreme Court vacated our decision and remanded for us to "address the impact, if any, of MCL 500.3114 on whether the plaintiff is eligible to claim benefits through the [MACP]." Steanhouse II, 512 Mich. at 928. At our direction, the parties filed supplemental briefs on the issue raised in the Supreme Court's remand order. We now turn to its consideration.
Steanhouse argues that multiple provisions of the no-fault act, properly considered as a whole, establish his entitlement to benefits through the MACP.
Although this appeal arises from the denial of defendants' motion for summary disposition, resolution of this legal issue depends entirely on the interpretation of the no-fault act. "We review de novo both the denial of a motion for summary disposition and questions of statutory interpretation." Rouch World, LLC v Dep't of Civil Rights, 510 Mich. 398, 410; 987 N.W.2d 501 (2022). On de novo review, we give "respectful consideration, but no deference" to the trial court's rulings. Wasik v Auto Club Ins Assoc, 341 Mich.App. 691, 695; 992 N.W.2d 332 (2022).
As we consider whether MCL 500.3114 has any impact on Steanhouse's eligibility for benefits, we begin with the plain language of the no-fault act.[1] See South Dearborn Environmental Improvement Ass'n, Inc v Dep't of Environmental Quality, 502 Mich. 349, 360-361; 917 N.W.2d 603 (2018) (). "If the statute's language is clear and unambiguous, we assume that the Legislature intended its plain meaning, and we enforce the statute as written." Rouch World, 510 Mich. at 410 (cleaned up). When interpreting various terms in the no-fault act, we must consider them in the context of the act as a whole, giving effect as much as possible to every word and phrase. Diallo v LaRochelle, 310 Mich.App. 411, 418; 871 N.W.2d 724 (2015). Similarly, statutory terms "cannot be viewed in isolation, but must be construed in accordance with the surrounding text and the statutory scheme." McQueer v Perfect Fence Co, 502 Mich. 276, 286; 917 N.W.2d 584 (2018) (cleaned up). Although an unambiguous statute must be applied as written, we also recognize that the no-fault act is remedial and should be" 'liberally construed in favor of the persons who are intended to benefit from it.'" Griffin v Trumbull Ins Co, 509 Mich. 484, 497; 983 N.W.2d 760 (2022), quoting Putkamer v Transamerica Ins Corp of America, 454 Mich. 626, 631; 563 N.W.2d 683 (1997).
To understand whether MCL 500.3114 impacts Steanhouse's eligibility for benefits, we begin with MCL 500.3111, which "pertains to Michigan residents involved in out-of-state accidents." Dye v Esurance Prop &Cas Ins Co, 504 Mich. 167, 190 n 60; 934 N.W.2d 674 (2019). MCL 500.3111 provides:
Personal protection insurance benefits are payable for accidental bodily injury suffered in an accident occurring out of this state, if the accident occurs within the United States, . . . and the person whose injury is the basis of the claim was at the time of the accident a named insured under a personal protection insurance policy, the spouse of a named insured, a relative of either domiciled in the same household, or an occupant of a vehicle involved in the accident, if the occupant was a resident of this state or if the owner or registrant of the vehicle was insured under a personal protection insurance policy or provided security approved by the secretary of state under section 3101(5). [Emphasis added.]
Before the 2019 amendments to the no-fault act, the emphasized clause of MCL 500.3111 provided that benefits were payable to "an occupant of a vehicle involved in the accident whose owner or registrant was insured under a personal protection insurance policy ...." MCL 500.3111, as enacted by 1972 PA 294. While the prior version of the statute conditioned eligibility on the existence of an applicable insurance policy, the statute now makes PIP benefits payable for injuries suffered in an out-of-state accident if "an occupant of a vehicle involved in the accident" was a Michigan resident, without regard to an applicable policy. Thus, looking at MCL 500.3111 alone, PIP benefits "are payable" to Steanhouse because he is a Michigan resident who was injured while an occupant of a vehicle involved in an out-of-state accident.
The inquiry in this case does not end there, however. We...
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