Michigan Court Reaffirms That Auto Insurers Cannot Use Policy Exclusions to Deny Michigan No-Fault (PIP) Benefits
A recent Michigan Court of Appeals decision has once again confirmed a cornerstone of Michigan No-Fault law:
Insurance companies cannot avoid paying Personal Injury Protection (PIP) benefits with policy exclusions that reduce coverage below what the No-Fault Act requires.
In Bronson Health Care Group, Inc. v. Farm Bureau General Insurance Co. of Michigan (Sept. 24, 2025), the court applied a principle that has guided Michigan auto law for decades:
The No-Fault Act sets the floor for mandatory PIP coverage.
Insurers may provide more protection — but they cannot provide less.
This case doesn’t change the law. Instead, it reinforces protections that have always been part of the No-Fault system.
What Happened?
The case arose after a patient was injured in an automobile accident and received treatment from Bronson Health Care. Bronson submitted its medical bills to the patient’s auto insurer, Farm Bureau General Insurance Company of Michigan, seeking payment under the patient’s Personal Injury Protection (PIP) benefits. Farm Bureau denied the claim, relying on an “owned-vehicle exclusion” in the insurance policy and arguing that the injured person was not eligible for PIP benefits because they owned a vehicle that was not listed on the policy. Bronson filed suit to obtain payment.
The Court of Appeals held that the exclusion could not override the statute — a straightforward application of MCL 500.3114 and long-standing Michigan precedent.
Why the Court Rejected the Exclusion
Michigan law has always been clear:
- PIP benefits are defined by statute
- A person entitled to PIP under MCL 500.3114 cannot lose those benefits due to conflicting contract language
- Policy exclusions that reduce PIP benefits below the statutory minimum are invalid
The court simply reaffirmed these principles.
This is consistent with decades of Michigan cases holding that the No-Fault Act governs entitlement to benefits — not insurer-written exclusions.
Why This Decision Still Matters Today
Although the rule is not new, this published decision is important for several reasons:
It pushes back against a trend of more aggressive PIP denials post-reform
After the 2019 No-Fault amendments, some insurers increased the use of:
- unlisted-vehicle exclusions
- household exclusions
- failure-to-insure exclusions
- owned-vehicle exclusions
Courts continue to reject these attempts when they conflict with statutory entitlement.
It provides an up-to-date, published reminder for adjusters and trial courts
Having current appellate authority helps injured people, providers, and attorneys challenge improper denials more efficiently.
It reassures Michigan crash victims that their rights haven’t changed
Even with reforms, insurers cannot contract around the No-Fault Act.
What This Means for Injured Drivers in Michigan
If you were injured in a crash:
You are still entitled to PIP benefits under the statute
That includes coverage for:
- medical treatment
- rehabilitation
- lost wages
- attendant care
- replacement services
Policy exclusions cannot eliminate your core PIP rights
Not even if the insurer claims:
- the vehicle wasn’t listed
- you owned a second vehicle
- you violated a policy condition
- there’s an exclusion written into the contract
Michigan courts consistently refuse to enforce exclusions that conflict with the No-Fault Act’s baseline requirements.
A denial does NOT mean you are not entitled to benefits
This case reinforces that many PIP denials are legally incorrect.
Why This Case Helps Your Clients
For many people in West Michigan, a PIP denial letter feels final.
But this decision serves as a reminder that:
The law — not the insurance contract — determines who receives PIP benefits.
What to Do If Your PIP Claim Was Denied
If you receive a PIP denial:
- Don’t assume the insurer is right
- Keep your medical bills and denial letters
- Contact an attorney familiar with Michigan No-Fault law
Many denials rely on exclusions that courts reject again and again.
How JKH Law Can Help
JKH Law is here to help people across Grand Rapids and West Michigan challenge improper No-Fault PIP denials and recover the benefits they are entitled to by law.
- Your rights come from the statute
- An insurer cannot contract around them
- You have the ability to challenge a denial and win
Get more information about your legal rights here:
Q: Does this new case change Michigan No-Fault law?
A: No. The decision simply reaffirms long-standing Michigan principles: the No-Fault Act sets the minimum level of PIP benefits, and insurers cannot use policy exclusions to reduce that coverage. The rules for who is entitled to PIP benefits remain the same.
Q: Can my auto insurer deny PIP benefits if my vehicle wasn’t listed on the policy?
A: No. Michigan courts have consistently held that “unlisted-vehicle” or “owned-vehicle” exclusions cannot override the statutory right to PIP benefits under MCL 500.3114. If you’re injured in a crash, you may still be entitled to full benefits.
Q: What if my insurer says I violated a policy condition?
A: Policy conditions or exclusions cannot eliminate the mandatory PIP coverage required by the Michigan No-Fault Act. Even if the insurer claims you broke a contract rule, you may still be legally entitled to benefits.
Q: How do I know if my PIP denial is valid?
A: Many denials are not. Insurers often rely on exclusions that courts have repeatedly rejected. If your claim was denied, it’s important to have the denial reviewed by an attorney familiar with Michigan No-Fault law.
Q: Does the Michigan No-Fault Act still guarantee PIP medical benefits after the 2019 reforms?
A: Yes. While reforms changed coverage levels and provider-payment rules, the basic entitlement to PIP benefits under MCL 500.3114 did not change for residents of Michigan. Insurers still cannot write policies that provide less than the statutory minimum.
Q: Should I contact an attorney if my insurer denies my PIP claim?
A: Yes. A denial does not mean you are not covered. Many injured people receive improper denials based on invalid exclusions. An attorney can help challenge the denial and ensure you receive the benefits owed under Michigan law.
