Involved, or not Involved, that is the Question

In Jamie Pike v Farm Bureau Mutual Insurance Company of Michigan, unpublished opinion per curiam of the Court of Appeals, issued November 27, 2018, the Michigan Court of Appeals examined MCL 500. 3101 as it relates to an uninsured vehicle’s involvement in a motor vehicle accident.

The owner of a motor vehicle is only entitled to PIP benefits for a bodily injury resulting from an accident involving a vehicle that maintains the proper security required by the code. Therefore, if an uninsured vehicle is involved in an accident, a plaintiff is not entitled to PIP benefits. However, there must be an active link between the uninsured motor vehicle and the subject accident. A passive link between an uninsured vehicle and the subject motor vehicle accident is simply not enough to satisfy summary disposition pursuant to MCL 500.3101(1).

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