Adam v. Bell, 311 Mich. App. 528

On July 3, 2011 Cynthia Adam was injured in an auto accident involving drivers Susan and Minerva Bell.
Adam sued State Farm in March 2012 for no-fault PIP benefits; that claim was settled and released by agreement in October 2012 and dismissed with prejudice in November 2012.
In January 2013 Adam filed a third-party complaint asserting negligence/owner liability against the Bells and a breach-of-contract claim for uninsured motorist (UM) benefits against State Farm.
State Farm moved for summary disposition arguing res judicata barred the UM claim because it arose from the same accident and could have been litigated with the earlier PIP action.
The trial court granted summary disposition for State Farm; the Court of Appeals reversed, finding res judicata did not bar the UM claim because PIP and UM claims differ materially in proof, motivation, and timing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether res judicata bars the UM claim because it arose from the same accident as the earlier PIP suit	Adam: UM claim was distinct and not ripe at time of PIP suit; could not practically be litigated earlier	State Farm: Both claims arise from same transaction; UM should have been joined and is therefore barred	Court: Res judicata does not bar UM claim — PIP and UM are pragmatically distinct (different proof, motivation, and timing)

Adair v. State, 470 Mich. 105 (Mich. 2004) (announces Michigan's broad "same transactional test" for res judicata)
Pierson Sand & Gravel, Inc. v. Keeler Brass Co., 460 Mich. 372 (Mich. 1999) (policy objectives of res judicata explained)
McCormick v. Carrier, 487 Mich. 180 (Mich. 2010) (proof required to establish serious impairment threshold)
Shavers v. Attorney General, 402 Mich. 554 (Mich. 1978) (purpose of PIP benefits is prompt payment for care and recovery)
Rory v. Continental Ins. Co., 262 Mich. App. 679 (Mich. Ct. App. 2004) (discusses ripeness and practical limitations of filing UM claims)