“Be More Specific:” Supreme Court Requires Claimants Report Symptoms Traceable to a Diagnosed Injury Within One Year

On May 5, 2016, the Court of Appeals issued its published opinion in Dillon v State Farm, 315 Mich App 339, 889 NW2d 720 (2016). In Dillon, the plaintiff was struck by a vehicle and initially reported injuries to her lower back and left shoulder. She never mentioned any injury to her left hip. However, nearly three years after the accident, she complained of hip pain. State Farm argued that it had not received notice of a hip injury within one year of the accident pursuant to MCL 500.3145(1).

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