Dawoud v. State Farm Mutual Automobile Insurance Co., 317 Mich. App. 517

Plaintiffs Dawoud, Kamel, and Essa were involved in a motor vehicle collision and applied for no‑fault benefits; State Farm was assigned the claim.
Service providers Grace Transportation and Utica Physical Therapy intervened to pursue direct payment of their bills by State Farm.
Plaintiffs’ claims were dismissed with prejudice for discovery violations (missed depositions, failed to comply with orders).
State Farm moved for summary disposition arguing the underlying dismissal barred the service providers’ derivative PIP claims as an adjudication on the merits.
Service providers argued they had standing to sue under MCL 500.3112 and that their claims should not be barred by the underlying dismissal.
Trial court granted summary disposition for State Farm; the appellate court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether service providers’ PIP claims survive if plaintiffs’ underlying claim was dismissed for discovery violations	Service providers rely on standing under MCL 500.3112 and Wyoming Chiropractic to sue insurer directly.	Dismissal for discovery violations constitutes an adjudication on the merits, barring derivative claims.	Derivative claims barred; dismissal treated as adjudication on the merits.
Whether dismissal for discovery violations differs from a substantive merits dismissal for purposes of bar to derivative claims	Failure to comply should not invalidate providers’ PIP claims on substantive grounds.	Once underlying claim is barred, derivative PIP claims cannot proceed.	No difference; both lead to preclusion of derivative claims.

Wyoming Chiropractic Health Clinic, PC v Auto-Owners Ins Co, 308 Mich App 389 (2014) (held provider standing to sue insurer under MCL 500.3112)
Covenant Med Ctr v State Farm Mut Auto Ins Co, 313 Mich App 50 (2015) (derivative/no‑fault claims affected by merits rulings)
Moody v Home Owners Ins Co, 304 Mich App 415 (2014) (derivative claims depend on underlying merits)