The 2019 amendments to the No-Fault Act (NFA) as to Michigan residents injured as passengers in an out-of-state accident; PIP benefits through the Michigan Assigned Claims Plan (MACP); Steanhouse v Michigan Auto Ins Placement Facility (On Remand) (Steanhouse III); Michigan Automobile Insurance Placement Facility (MAIPF)

Relying on Steanhouse III, the court concluded that defendants-MAIPF and MACP “were entitled to summary disposition, and the trial court did not err by granting” them summary disposition in this case involving a claim for PIP benefits. Plaintiff provided physical therapy services to a Michigan resident who was a passenger injured in an auto accident in Ohio. Plaintiff argued that the Legislature, through its 2019 amendments to the NFA, “intended for Michigan residents who are injured as passengers in an out-of-state car accident to be able to claim PIP benefits through the MACP. According to plaintiff, MCL 500.3111 and MCL 500.3114(4) create a separate path to PIP-benefit eligibility through the MACP for out-of-state accidents irrespective of the language contained in MCL 500.3172(1) because MCL 500.3172(1) only applies to in-state accidents.” Plaintiff claimed that as a result, defendants were not entitled to summary disposition. The court noted that it “squarely addressed and rejected this same argument in Steanhouse III,” which determined “that ‘MCL 500.3114 [did] not impact Steanhouse’s eligibility to claim benefits through the MACP’ and reaffirm[ed] that MCL 500.3172(1) controlled the issue and ‘require[d] an individual claiming PIP benefits through the MACP to show that the accident giving rise to the claim occurred in Michigan.’” The court concluded that “Steanhouse III is a precedentially binding case, and” controlled the outcome here. Affirmed.