Michael Barnett Spencer v. State Farm Mutual Automobile Ins Co, 332111

Michael Spencer was injured in a 2013 car accident and sought reimbursement under his no-fault PIP policy for replacement (in-home) services performed by his sister, Barbara Cooper.
Cooper submitted weekly activity "calendars;" State Farm reimbursed Cooper through January 15, 2014, then denied further reimbursement. Spencer sued for breach of contract and declaratory relief.
State Farm moved for summary disposition under MCR 2.116(C)(10), arguing Spencer made fraudulent deposition statements about receiving daily assistance between January 2015 and August 2015 that Cooper did not provide.
The trial court granted summary disposition for State Farm based on the policy’s fraud-exclusion clause. State Farm bore the burden to prove the exclusion applied.
On appeal, the Court of Appeals reversed, holding material factual disputes (credibility, context of deposition answers, and absence of documentary proof contradicting Spencer) made summary disposition inappropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Spencer’s deposition statements were fraudulent such that the policy’s fraud exclusion bars coverage	Spencer’s answers were taken out of context; he was not seeking reimbursement for the disputed period and his "yes" answer was to a confusing question about calendars	Spencer’s testimony that Cooper gave assistance "every day" from Jan 2015–Aug 2015 contradicts Cooper’s testimony and her calendars, proving false statements	Reversed: genuine issues of material fact exist about falsity; deposition excerpts alone do not establish fraud as a matter of law
Whether State Farm met its burden to prove the exclusionary defense on summary disposition	The record does not conclusively establish all elements of fraud (materiality, falsity, knowledge/recklessness, intent to induce reliance)	State Farm argued inconsistencies in testimony establish the elements of fraud and entitlement to judgment	Held for Spencer: insurer failed to eliminate factual disputes on all elements required to void coverage for fraud
Whether credibility and intent issues allow summary disposition	Spencer argued credibility and mental-state issues preclude summary disposition; trial should resolve them	State Farm argued deposition testimony was clear enough to permit no genuine dispute	Held: credibility and intent are classic jury-triable issues; summary disposition was improper

Johnson v Recca, 492 Mich. 169 (De novo review of summary disposition)
Maiden v Rozwood, 461 Mich. 109 (summary-disposition evidence standards)
West v General Motors Corp., 469 Mich. 177 (definition of genuine issue of material fact)
Vanguard Ins Co v Bolt, 204 Mich. App. 271 (credibility issues defeat summary disposition)
Auto-Owners Ins Co v Seils, 310 Mich. App. 132 (insurer bears burden to prove policy exclusion)
Bahri v IDS Property Cas Ins Co, 308 Mich. App. 420 (fraud exclusion may support summary disposition where evidence is indisputable)
Mina v Gen Star Indemnity Co, 218 Mich. App. 678 (elements of fraud for voiding policy)
White v Taylor Distributing Co, 275 Mich. App. 615 (courts may not resolve credibility on summary disposition)
Burkhardt v Bailey, 260 Mich. App. 636 (same)
Arbelius v Poletti, 188 Mich. App. 14 (trial court may not weigh credibility at summary judgment)
In re Handelsman, 266 Mich. App. 433 (intent/state-of-mind issues typically inappropriate for summary disposition)