Secrest Wardle MI PIP Monthly

Case Law Update

• Laurel Hill Management Services, Inc. v La-Z-Boy, Inc., Sixth Circuit Court of Appeals, issued August 19, 2026

• Demptster v State Farm Mutual Automobile Insurance Co., unpublished opinion per curiam of the Court of Appeals, issued August 20, 2026 (Docket No.s 374546; 375033)

Trending Topics in PIP Litigation

• Recent order of Priority Issues with MAIPF

• Cooks v Citizens Insurance Company of the Midwest, unpublished opinion per curiam of the Court of Appeals, issued August 13, 2026 (Docket No. 375350)

• Banker v Citizens United Reciprocal Exchange (CURE), unpublished opinion per curiam of the Court of Appeals, issued August 10, 2026 (Docket No. 374356)

• Melton v Ziadeh/Citizens Insurance Co. v Progressive Michigan Insurance Co., unpublished opinion per curiam of the Court of Appeals, issued August 11, 2026 Docket No. 375100)

Case Law Update

• Frownfelter v Esurance Property and Casualty Company, Michigan Supreme Court decision, issued July 22, 2026

• Canty v Mason, Michigan Supreme Court decision, issued July 27, 2026

Trending Topics in PIP Litigation

• Court of Appeals Finally Rules on NervoMatrix Efficacy

• SNM Physical Therapy LLC v Citizens Insurance Company of the Midwest, unpublished opinion per curiam of the Court of Appeals, issued July 17, 2026

Case Law Update

• Abdulla v Progressive SE. Ins. Co., ___ NW3d ___ (Mich, July 7, 2026)

• Citizens United Reciprocal Exchange v Barnes, unpublished opinion per curiam of the Court of Appeals, issued June 23, 2026

• Zaki Anesthesia, PLLC v State Farm Mutual Automobile Insurance Co., unpublished opinion per curiam of the Court of Appeals, issued June 16, 2026

Trending Topics in PIP Litigation

• Remanded MSC Cases

• Hammock/C-Spine Orthopedics, PLLC v Farm Bureau, unpublished opinion per curiam of the Court of Appeals, issued July 7, 2026

• Swoope v Citizens Insurance Company of the Midwest, unpublished opinion per curiam of the Court of Appeals, issued June 18, 2026

Case Law Update

• Michigan Ambulatory Surgical Center and Phase One Rehab v Progressive Marathon Insurance Company, unpublished opinion per curiam of the Court of Appeals, issued May 20, 2026 (Docket No. 373314)

• Zielinski v Auto-Owners Ins. Co., No. 371692, 2026 WL 1699526, at *1 (Mich Ct App June 11, 2026)

Trending Topics in PIP Litigation

• Courts Reject Appeals From Stip Orders

• Saad Yousif Ishoo and Marena Saad Ishoo v Farm Bureau General Insurance Company of Michigan, unpublished opinion per curiam of the Court of Appeals, issued May 21, 2026 (Docket No. 370759)

• Stanley v Farmers Ins. Exc., No. 374881, 2026 WL 1674086, at *1 (Mich Ct App June 9, 2026)

Case Law Update

• Jawad A. Shah, P.C., Alliance Anesthesia, PLLC, Insight Anesthesia, PLLC and Insight Radiologists, P.C. v Auto Club Ins Assoc, unpublished opinion per curiam of the Court of Appeals, issued April 20, 2026 (Docket No. 372543)

• MemberSelect Ins Co v Michael James Clancy, PR of the Estate of Connor James Clancy and Anthony Dwayne Magee and Debbie Magee, unpublished opinion per curiam of the Court of Appeals, issued April 23, 2026 (Docket No. 372802)

Trending Topics in PIP Litigation

• Staged accident fraud recovery

• Uber Technologies, Inc., et al. v Powell, et al., 2:26-cv-02195, U.S. District Court for the Eastern District of New York, filed April 14, 2026

Case Law Update

• Kermit Lamark Copeland v Allstate Ins Co, ___ Mich App___; ___ NW2d ___ (2026) (Docket No. 373748)

• Northland Radiology, Inc. v Allstate Fire and Casualty Ins Co, ___ Mich App ___; ___ NW2d ___ (2026) (Docket No. 374214)

Trending Topics in PIP Litigation

• Equitable Rescission of a Policy

• Janice Sherman v Progressive Michigan Insurance Company and John Doe, ___ Mich ___ (2026) (Docket No. 167826)

Case Law Update

• Mary Free Bed Rehab Hosp v Esurance Prop and Cas Ins Co and U.S. Auto Assoc,

___ Mich App ___; ___ NW2d ___ (2026) (Docket No. 370846)

• Spectrum Health Hosp d/b/a Spectrum Health and Corewell Health, and Spectrum Health Primary Care Partners v Auto-Owners Ins Co, unpublished opinion per curiam of the Court of Appeals, issued February 18, 2026 (Docket No. 347980)

Trending Topics in PIP Litigation

• Unlawful Taking Exclusion of MCL 500.3113(a)

• Carlonda Naishe Swoope v Citizens Ins Co of the Midwest, ___ Mich ___ (2026) (Docket No. 166790)

Case Law Update

• Neal J. Campbell v State Farm Mut Auto Ins Co, Auto Club Ins Assoc and MAIPF, unpublished opinion per curiam of the Court of Appeals, issued January 15, 2026 (Docket No. 371663)

• Nader Kourani v American Select Ins Co, unpublished opinion per curiam of the Court of Appeals, issued January 22, 2026 (Docket No. 373757)

Trending Topics in PIP Litigation

• Independent Contractors versus Employees under MCL 500.3114(3)

• Univ of Michigan Regents v State Farm Mut Auto Ins Co, Auto-Owners Ins Co, Home-Owners Ins. Co, Geico Gen Ins Co, Geico Indem Co, Gov't Employees Ins Co, MACP and MAIPF, unpublished opinion per curiam of the Court of Appeals, issued January 20, 2026 (Docket Nos. 372975, 372990 and 373877)

Case Law Update

• Leo Pellot, Individually and Next Friend of AKP, Minor v State Farm Mut Auto Ins Co and MAIPF, MACP and Currently Unnamed Assignee of the MACP, unpublished opinion per curiam of the Court of Appeals, issued December 12, 2025 (Docket No. 371648)

• Walter Love and Thrive Physical Therapy LLC v Lashawn Rudolph and Allstate Prop and Casualty Ins Co, Allstate Ins Co, Auto Club Group Ins Comp and The Hanover Ins Co, ___ Mich App ___ (2025)(Docket No. 369895)

Trending Topics in PIP Litigation

• "Incurred" PIP Benefits Under MCL 500.3107

• S. Baxter Jones v Esurance Ins Co, unpublished per curiam opinion of the Court of Appeals, issued November 25, 2025 (Docket No. 370782)

Case Law Update

• Dominique Bellamy, Personal Representative of the Estate of Ericka Bellamy v Citizens United Reciprocal Exch, unpublished opinion per curiam of the Court of Appeals, issued November 17, 2025 (Docket No. 371648)

• Phase One Rehab, LLC v Allstate Prop & Cas Ins Co, ___ Mich App ___ (2025) (Docket No. 369413)

Trending Topics in PIP Litigation

• Effect of Related Tort Claims on PIP Benefits Under MCL 500.3116

• Sharon Call and James Call and Frankenmuth Ins Co v L & KJ Enterprises, LLC d/b/a Family Tire Service of Manistee, ___ Mich App ___ (2025)(Docket No. 366229)