Bronson Methodist Hospital v. Michigan Assigned Claims Facility, 298 Mich. App. 192

This is a consolidation of two no-fault cases involving MACF and Progressive Insurance.
Progressive issued a no-fault policy to Owsiany, insuring a vehicle owned by Pillars who is an excluded driver.
Pillars was driving the insured vehicle when the accident occurred, and Progressive denied PIP benefits.
The policy includes a named-driver exclusion: excluded drivers render all liability coverage void when operating the insured vehicle.
At issue is whether Pillars is entitled to PIP benefits despite the exclusion and whether the security required by MCL 500.3101 was in effect.
The trial court granted summary disposition for MACF and Progressive; the appellate court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do the named-driver exclusion and MCL 500.3113(b) bar PIP benefits for Pillars?	Iqbal supports coverage because security exists via vehicle insurance.	Exclusion voids coverage; security not in effect when excluded driver operates the vehicle.	Pillars not entitled; exclusion applies; no PIP benefits.
Is Iqbal controlling or distinguishable here?	Relies on Iqbal to argue vehicle security suffices.	Iqbal is (factually/legally) distinguishable; the present case involves an excluded driver.	Iqbal distinguished; not controlling.
Should the MACF be ordered to assign the claim to another no-fault insurer if necessary?	Requests assignment to another insurer if exclusion stands.	No argument or authority; issue abandoned.	Issue abandoned; no assignment ordered.

Iqbal v Bristol West Ins Group, 278 Mich App 31 (2008) (security linked to vehicle; Iqbal distinguished here)
Cruz v State Farm Mut Auto Ins Co, 466 Mich 588 (2002) (public policy and statutory interaction relevant to PIP)
Roberts v Farmers Ins Exch, 275 Mich App 58 (2007) (discussion of exclusions and policy language)
Farmers Ins Exch v Kurzmann, 257 Mich App 412 (2003) (enforce plain meaning of policy language)