Healthcare Providers Cannot Circumvent Eligibility Requirements Of No-Fault Act By Invoking Their Direct Cause Of Action Under MCL 500.3112
A healthcare provider that treats an injured person for an accidental bodily injury is not entitled to recover no-fault personal protection insurance (PIP) benefits under MCL 500.3112 when the injured person is an "owner" of an uninsured motor vehicle under MCL 500.3101(3)(l)(i) and therefore ineligible to receive PIP benefits under MCL 500.3113(b).
Michigan Supreme Court Holds Exclusive Vehicle Control Creates Ownership Under the No-Fault Act
As the sole member of the limited-liability company that held title to the tractor, plaintiff had the exclusive, unsupervised right to use, maintain, and make all decisions regarding the vehicle for more than 30 days, which comported with ownership, regardless of the fact that title was held by his single-member LLC.