Bronson Health Care Group Inc v. Usaa Casualty Insurance Company, 966 N.W.2d 393

Plaintiff Bronson sought $5,411.22 from USAA for emergency-department care provided to insured Brian Moore from two visits (May 8 and May 23, 2018).
On both visits Moore signed a hospital "consent-to-treat" form that included an open-ended assignment of his rights to pursue insurance payment; each form was signed before the medical services were rendered that day.
Bronson sued USAA under Moore's no-fault (PIP) coverage, relying on those assignments to collect directly from USAA.
USAA moved for summary disposition, arguing the pre-treatment assignments were void under MCL 500.3143 (assignment of future benefits prohibited).
The district court denied USAA’s motion (finding contemporaneous execution/treatment); the circuit court denied leave to appeal; the Court of Appeals granted leave and reversed, holding the assignments void and directing judgment for USAA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether assignment forms signed before services are void under MCL 500.3143	Bronson: PIP benefits pay as loss accrues; loss accrues when expense is incurred; an expense is incurred when a patient becomes contractually liable (signs the form), so the assignments conveyed presently payable benefits	USAA: At the time of signing Moore had no right to benefits because services had not yet been provided; the forms assigned rights to benefits payable in the future and are void under MCL 500.3143	Court: Assignments signed before services were rendered concerned future-payable benefits and are void under MCL 500.3143; reverse and remand for judgment for USAA

Covenant Med Ctr, Inc v State Farm Mut Auto Ins Co, 500 Mich 191 (Mich. 2017) (Supreme Court: providers lack independent statutory cause to sue insurer; endorses assignment of past or presently due benefits but not future benefits)
Rory v Continental Ins Co, 473 Mich 457 (Mich. 2005) (rules for contract interpretation; give words their plain meaning)
Proudfoot v State Farm Mut Ins Co, 469 Mich 476 (Mich. 2003) (definition of "incur" and discussion when liability arises; signing a contract can incur liability depending on context)
Clark v Al-Amin, 309 Mich App 387 (Mich. Ct. App. 2015) (an insured becomes liable for an expense when he accepts medical treatment)
New Amsterdam Cas Co v Sokolowski, 374 Mich 340 (Mich. 1965) (ambiguities in contract may be explained by testimony)
McIntosh v Groomes, 227 Mich 215 (Mich. 1924) (cardinal rule: ascertain parties' intent; give contract words plain meaning)
Johnson v Vanderkooi, 502 Mich 751 (Mich. 2018) (standard of review for summary disposition)