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Beyond Absurd: Court of Appeals Rejects Absurd Results Doctrine and Enforces Unambiguous Homeowner’s Policy
In Fabatz v Auto-Owners Ins Co, the Michigan Court of Appeals stressed that property and casualty insurance policies are to be interpreted as any other species of contract. Unambiguous language must be given effect to the extent it is not violative of any law or public policy.
Significantly, the appellate panel rejected Plaintiffs’ contention that the absurd results doctrine should serve to invalidate certain policy provisions. In brief, the absurd results doctrine is a tool of statutory construction, enabling a court to depart from the plain meaning of a statute to avoid a ludicrous result. The Michigan Supreme Court effectively abolished the doctrine in People v McIntire, 461 Mich 147 (1999); however, some recent decisions hint at its return.
While Fabatz is an unpublished opinion and therefore is non-binding, it may serve as persuasive authority. In particular, the decision is notable for its rebuke of Plaintiffs’ efforts to extend the absurd results doctrine to a property and casualty insurance coverage dispute. It may serve as a tool to combat similar efforts in the future.
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