Entitlement to PIP Benefits – Michigan
Steanhouse v. Michigan Auto. Ins. Placement
Facility
--- N.W.3d ---, 2024 WL 1588626 (Mich. App. April 11, 2024)
The Michigan Court of Appeals reaffirmed its prior holding that
a claimant who resides in Michigan is not entitled to Personal
Protection Insurance (PIP) benefits through the Michigan Assigned
Claims Plan (MACP) for injuries arising from an out-of-state car
accident. In so holding, the appellate court reversed the judgment
of the trial court and remanded the case to that court for further
proceedings.
In 2019, plaintiff Markise Steanhouse was injured in a motor
vehicle accident in Ohio. Steanhouse applied for PIP benefits
through the MACP, but he was denied coverage. Steanhouse filed
suit, and defendants, Michigan Automobile Insurance Placement
Facility and MACP, filed a motion for summary disposition, arguing
that in order to claim PIP benefits, the accident giving rise to
the claim must have occurred in the
