Dragen Perkovic v. Zurich American Insurance Company, 152484

On Feb 28, 2009 Perkovic was injured in a Nebraska semitruck crash and was treated at The Nebraska Medical Center (NMC).
On Apr 30, 2009 NMC mailed Perkovic’s medical records and bills to Zurich (his employer’s insurer); Zurich returned them on May 19, 2009 stating “No injury report on file.”
Perkovic sued for unpaid PIP benefits on Aug 11, 2009 naming his personal insurer; he added Zurich as a defendant only on Mar 25, 2010 (≈13 months after the accident).
Zurich moved for summary disposition under MCR 2.116(C)(7), arguing MCL 500.3145(1)’s one‑year limitations bar applied because Zurich had received no adequate written notice or payment within one year.
The trial court and Court of Appeals agreed with Zurich; the Michigan Supreme Court reversed, holding the NMC submission satisfied MCL 500.3145(1) because it contained the statutory information and was sent “in behalf” of Perkovic.

Issue	Perkovic's Argument	Zurich's Argument	Held
Whether medical records/bills sent by a nonparty medical provider within 1 year satisfy the written‑notice requirement of MCL 500.3145(1)	NMC’s records/bills contained the claimant’s name/address and the time, place, and nature of injury and were sent on his behalf, satisfying the statute	Notices must indicate an intent to claim PIP (i.e., be sent by someone claiming benefits or clearly assert a PIP claim); NMC’s materials did not do so	Majority: Yes — the documents satisfied MCL 500.3145(1) because they contained the required information and were sent “in behalf” of the claimant; statute does not require explicit language asserting a PIP claim. Dissent: No — notice must be given by or on behalf of someone actively claiming PIP benefits at the time of notice.

Dozier v. State Farm Mut. Auto. Ins. Co., 95 Mich. App. 121 (1980) (Court of Appeals endorsed "substantial compliance" approach to §3145(1) notice)
Walden v. Auto-Owners Ins. Co., 105 Mich. App. 528 (1981) (notice that substantially complied with statutory contents can suffice)
Heikkinen v. Aetna Cas. & Surety Co., 124 Mich. App. 459 (1981) (documents meeting content requirements may nonetheless fail if not presented as a claim for PIP)
Jesperson v. Auto Club Ins. Ass’n, 499 Mich. 29 (2016) (statutory interpretation and one‑year limitations analysis under the no‑fault act)