Michigan Court Rules Parked Vehicle Not ‘Involved’ in Accident for PPI Claims

The Michigan Court of Appeals has ruled that a properly parked and unoccupied vehicle struck by a moving car is not considered "involved in the accident" for purposes of assigning responsibility to property protection insurance (PPI) benefits under Michigan law (MCL 500.3125). The case arose from a 2022 incident where a stationary Ford Escape was hit and propelled into a pizzeria by a vehicle that apparently crashed after the driver fell asleep at the wheel. The parked car's owner was insured by State Farm Mutual Auto Insurance Company. Plaintiffs, who provided property insurance for the building and pizzeria, sought subrogation of PPI benefits from State Farm after paying $64,000, asserting the parked vehicle’s involvement in the accident. However, the Court, citing precedent from Turner v Auto Club Ins Ass'n and Miller v Auto-Owners Ins Co, found that the parked and unoccupied vehicle was akin to a stationary object such as a tree or signpost, neither actively contributing to nor being "used as a motor vehicle" in causing the accident. The ruling emphasized that the parked vehicle did not undergo maintenance, experience mechanical failure, or play an active role and was merely passively struck and pushed forward. Consequently, the insurer was not liable for PPI benefits. This decision clarifies the interpretation of "involvement" under no-fault insurance law in Michigan, limiting PPI responsibility to vehicles actively contributing to accidents. The 11-page opinion (Fremont Insurance Co et al. v. State Farm Mutual Auto Insurance Co) reinforces legal standards surrounding parked vehicles and accident liability, impacting insurers, property insurers, and legal professionals handling similar subrogation claims in the state.