Entitlement to PIP Benefits: Motor Vehicle Must ‘Actively Contribute’ to Accident in Order to be Considered “Involved” under MCL 500.3113

In Robert Cornelius v Michigan Assigned Claims Plan, an unpublished decision of the Court of Appeals issued on February 27, 2018 (Docket No. 336074), the Michigan Court of Appeals upheld the trial court’s denial of Defendant’s Motion for Summary Disposition, finding that MCL 500.3113 did not bar Plaintiff’s claim for PIP benefits where two collisions constituted separate accidents. While Cornelius is an unpublished opinion and therefore not binding authority, it stands for the proposition that a Court must separately analyze whether each vehicle “actively influenced” the collision in order to determine involvement for purposes of MCL 500.3113(b).

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