Action seeking PIP benefits; MCL 500.3172; Domicile; MCL 500.3114(1); Grange Ins Co of MI v Lawrence; Domicile factors under Workman v Detroit Auto Inter-Ins Exch & Dairyland Ins Co v Auto Owners Ins Co; Whether a claimant is dependent on his or her parents for support; Mapp v Progressive Ins Co; Michigan Auto Insurance Placement Facility (MAIPF)

The court held that the trial court did not err by granting defendant-insurer summary disposition of plaintiff’s action seeking PIP benefits. Plaintiff sued defendant (an insurer assigned by MAIPF) seeking coverage for injuries she sustained in a car crash. Defendant claimed plaintiff was ineligible for PIP benefits because she had other available coverage through her parents’ insurer, and because she “knowingly made materially false statements” in her application for benefits to the MAIPF. The trial court agreed and granted its motion. On appeal, the court rejected plaintiff’s argument that the trial court erred by finding there was no genuine issue of material fact regarding her domicile at the time of the accident. Applying the Workman and Dairyland factors, the court found she “failed to establish a question of material fact regarding her domicile.” Although she emphasized “the first factor regarding her subjective or declared intent to remain with her parents, this factor [did] not favor either of the parties because there was no evidence presented as to whether plaintiff intended to stay with her parents indefinitely.” As to the second factor, “the relationship between plaintiff and her parents appeared to be informal.” Under the third factor, she “clearly lived upon the same premises as her parents, since she had a bedroom in their house.” And as to the fourth factor, plaintiff testified she kept an “apartment ‘in [her] inventory,’ but she received mail and maintained her belongings at her parents’ house.” The remaining factors, “which are particularly tailored to plaintiff’s situation as an adult child of her insured parents, strongly indicate[d] that plaintiff was domiciled at her parents’ house.” Given how strongly the factors indicated “that plaintiff was domiciled with her parents, reasonable minds would not disagree on the issue.” Affirmed.