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Court of Appeals May Invoke Rarely-Used Conflict Procedure to Reevaluate the Application of Res Judicata to Successive PIP and UM Suits

Appellate, Motor Vehicle Litigation / February 24, 2016

In Adam v State Farm, ___ Mich App ___; ___ NW2d___ (2015) (Docket No. 319778), the Court of Appeals held that res judicata, or claim preclusion, did not apply where the plaintiff filed a PIP case, settled that case and voluntarily dismissed it, and then filed an uninsured motorist (“UM”) claim against the same carrier, relative to the same accident….


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