The Michigan Court of Appeals has ruled that individuals injured in auto accidents while not inside a vehicle cannot claim personal protection insurance (PIP) medical benefits if they opted out of medical coverage on their insurance policy. This decision, made on October 15, 2026, affects how no-fault benefits are accessed under the Michigan Assigned Claims Plan (MACP) and clarifies the eligibility criteria for such claims.
The case, Gary Jack Van Heusen v. Michigan Automobile Insurance Placement Facility (Docket No. 373182), centers around Gary Jack Van Heusen, who was injured in a multi-vehicle accident on December 20, 2022. Van Heusen was hit by another vehicle while assessing the damage to his own car after being struck from behind. He sustained serious injuries, including a broken leg and a pulmonary embolism, leading to significant medical expenses.
At the time of the accident, Van Heusen had an auto insurance policy that included PIP coverage for certain benefits but excluded medical coverage due to his election to opt out, citing coverage under Medicare. After the accident, he sought PIP benefits under the MACP, but his claim was denied by the Michigan Automobile Insurance Placement Facility (MAIPF), which argued that he was not eligible for benefits because he had identifiable insurance coverage and had opted out of medical coverage.
Van Heusen then filed a lawsuit seeking declaratory relief and PIP benefits, which the trial court initially granted. However, the MAIPF appealed the decision, leading to this ruling by the Michigan Court of Appeals.
The court ruled in favor of the MAIPF, reversing the trial court's decision. The judges stated, "We hold that such a person may not claim such benefits under the MACP." The court's opinion emphasized that the no-fault act requires individuals to seek benefits from their own insurance policy unless specific exceptions apply. It noted that since Van Heusen had opted out of medical coverage, he could not claim benefits from the MACP.
The ruling clarified that under the Michigan no-fault law, individuals must have applicable insurance coverage to claim PIP benefits. The court explained that Van Heusen's policy, despite lacking medical coverage, was still considered a valid PIP policy, which disqualified him from seeking benefits through the MACP.
This decision has significant implications for individuals injured in auto accidents in Michigan. It reinforces the importance of understanding the coverage options available under no-fault insurance policies and the consequences of opting out of certain benefits. The ruling also underscores the legal complexities surrounding the no-fault system and the eligibility criteria for accessing benefits under the MACP.
Going forward, this ruling may affect how individuals approach their auto insurance policies, particularly regarding the decision to opt out of medical coverage. It serves as a reminder that while the no-fault system was designed to provide prompt and adequate compensation for accident victims, the choices made regarding coverage can have lasting impacts on an individual's ability to claim benefits.
As for next steps, it remains to be seen whether Van Heusen or the MAIPF will pursue further legal action. The court's ruling can potentially be appealed to the Michigan Supreme Court, but details regarding any such plans were not available in the court filing.