Court of Appeals Calls for Special Panel to Decide Whether Innocent Third Party Rule Survives in PIP Claims

In Bazzi v Sentinel Ins Co, ___ Mich App ___; ___ NW2d ___ (2016), a panel of the Michigan Court of Appeals recently held, in a case involving a claim for PIP benefits, that the innocent third party rule precluding the rescission of a contract for fraud as against an innocent third party did not survive the Supreme Court’s decision in Titan v Hyten, 491 Mich 547; 817 NW2d 562 (2012).  A different panel has now issued a published opinion disagreeing with the Bazzi decision and calling for a special conflict panel to take up the issue…

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