Car Accident Law – Michigan No-Fault Insurance Law – Health Care Law
Hospitals and health care providers generally have standing to bring claims for No-Fault insurance benefits against an insurer for care, products, and services they provide to a person hurt in a car accident. See, e.g., Chiropractors Rehab Group PC v State Farm Mutual Automobile Ins Co, 313 Mich App 113 (2015). However, the rights of health care providers to recover PIP benefits are dependent on the injured person being “eligible” for No-Fault benefits. An injured person may be ineligible for a number of reasons, including if they are driving an uninsured car that they own at the time of the crash, or if they steal or take a car unlawfully. See, e.g., MCL 500.3113(a)-(c).
In a recent unpublished case, the Court of Appeals ruled that a hospital’s claims for No-Fault benefits were not precluded by false statements made during examinations under oath (EUOs) that were subsequently clarified or explained by the injured person and others during their depositions. The court reasoned that inconsistent statements made by others should not preclude the statutory claims to No-Fault benefits made by the hospital and health care providers, who did not make any false statements. The case is Detroit Medical Center v Michigan Property and Casualty Guarantee Association and Michigan Assigned Claims Facility, unpublished disposition July 26, 2016, Court of Appeals No.: 326793.
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