Heather Lynn Hannay v. Department of Transportation, 497 Mich. 45

Two cases consolidated before the Michigan Supreme Court: Hannay v Dep’t of Transportation and Hunter v Sisco, involving motor vehicle collisions with government-owned vehicles and asserted damages against governmental entities.
Hannay alleged injuries from a salt-truck collision; the trial court awarded substantial work-loss damages, noneconomic damages, and expenses; MDOT appealed and Hannay cross-appealed.
Hunter alleged injuries from a dump-truck collision; the trial court denied summary disposition; the Court of Appeals reversed in part, holding noneconomic damages were not recoverable under the motor vehicle exception.
The Court of Appeals’ Hannay decision upheld the work-loss damages against a governmental entity; the Hunter decision held noneconomic damages were not recoverable under the motor vehicle exception.
The Supreme Court granted review to decide (a) whether economic damages (work loss) may be recovered under the motor vehicle exception and (b) whether noneconomic damages (pain and suffering, emotional distress) may be recovered, and to evaluate Hannay’s proof of work loss.
The Court holds that both economic and noneconomic damages may be recoverable, but Hannay’s specific work-loss claim based on proposed dental-hygienist wages was not proven with the required standard of proof and was remanded for recalculation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the motor vehicle exception waives immunity for economic damages.	Hannay: no-fault limits apply but economic damages flow from bodily injury.	MDOT: no-fault limits restrict damages and noneconomic damages only; economic damages may not be recoverable under the motor vehicle exception.	Yes; economic damages are recoverable if no-fault limitations are satisfied.
Whether the motor vehicle exception permits noneconomic damages (pain and suffering, emotional distress).	Hannay argued noneconomic damages flow from bodily injury and are recoverable if the no-fault thresholds are met.	MDOT argued noneconomic damages are not within the motor vehicle exception.	Yes; noneconomic damages are recoverable if the statutory no-fault thresholds are met.
Whether Hannay's claimed work loss as a dental hygienist satisfies the statutory work-loss standard.	Hannay would have been admitted to the program, completed it, and worked part-time as a dental hygienist; this would have caused measurable income loss.	The evidence was too speculative; the required conditions (admission, completion, licensure, employment) were not proven.	No; the evidence was contingent and speculative; remand for recalculation consistent with the opinion.

Wesche v Mecosta Co Rd Comm, 480 Mich 75 (2008) (defines bodily injury as a physical or corporeal injury; loss of consortium not a bodily injury)
Roberts v Detroit, 102 Mich 64; 60 NW 450 (1894) (early view on injury and damages; loss of consortium not a bodily injury)
Hall v City of Cadillac, 114 Mich 99; 72 NW 33 (1897) (damages that are natural consequences of injury are recoverable)
Gobler v Auto-Owners Ins Co, 428 Mich 51 (1987) (work-loss damages in no-fault context based on earned income; disaibility of contingent claims)
Sutter v Biggs, 377 Mich 80; 139 NW2d 684 (1966) (tort damages include all natural consequences; foreseeability governs quantum not existence)
Price v High Pointe Oil Co, Inc, 493 Mich 238; 828 NW2d 660 (2013) (tort-feasor liable for all natural consequences of wrongful act; with limits)