Michigan Court of Appeals Reinforces Serious Impairment Standard: A Picture is NOT Worth a Thousand Words

The Court of Appeals’ decision in Jones v Hammons prompts liability carriers to argue that plaintiffs must do more than present MRIs, CT scans, or diagnostic wordsmanship to meet the serious impairment threshold. From a defense perspective, the decision preserves McCormick and its progeny as vital, but Jones reinforces that plaintiffs cannot satisfy the statute by proving an injury alone. Courts will not infer functional impairment from imaging studies or diagnoses without evidentiary support connecting those findings to observable limitations. In keeping the focus on that distinction, insurers can more effectively challenge marginal threshold claims at the summary disposition stage and limit exposure to noneconomic damages.NFN re Jones v Hammons by Patrycja A. Klein