Fraudulent Insurance Act — Michigan
Williamson v AAA of Michigan
No.165131, 2024 WL 2947016 (Mich. June 11, 2024)
The Michigan Supreme Court reversed a lower appellate
court's decision and held that statements made during
discovery, after a lawsuit for No-Fault benefits had been filed,
can constitute a fraudulent insurance act under the Michigan
No-Fault Act (No-Fault Act).
In 2018, the plaintiff Charles Williamson, a pedestrian, was
struck by a car and sustained injuries. Pursuant to the No-Fault
Act, Williamson applied for Personal Injury Protection (PIP)
benefits through the Michigan Automobile Insurance Placement
Facility (MAIPF). Subsequently, the Michigan Assigned Claims Plan
(MACP) dispensed Williamson's claim to the defendant, AAA of
Michigan (AAA). However, AAA refused to pay the benefits and, in
response, Williamson commenced suit for breach of contract and
declaratory relief. Following Williamson's filing of the
suit, he died in an unrelated accident.
