In Ellis v Bello, Unpublished Court of Appeals Case No. 342770 (Decided June 11, 2019) Ellis (the plaintiff) purchased, registered, and insured a vehicle in the state of New York. Thereafter, Ellis moved to Michigan, but his vehicle remained registered in New York and insured under the New York insurance policy. Subsequently, Ellis was involved in an accident and brought a claim for PIP benefits against his auto-insurer as well as a third party claim against the other motorist involved in the accident. Ellis’ auto insurer argued that they did not have to pay PIP benefits because Ellis did not have a valid no-fault insurance policy in effect at the time of the accident due to his failure to maintain no-fault insurance and register his vehicle in Michigan. The trial court agreed with the insurer’s argument and the Court of Appeals affirmed. Also, because Ellis failed to secure a Michigan no-fault insurance policy, he was precluded from recovering non-economic losses from the alleged at-fault driver. In short, Michigan residents as well as non-residents who drive a vehicle in Michigan for more than 30 days, must comply with Michigan’s no-fault registration and insurance requirements to adequately protect themselves in case of an accident.
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