Michigan Head & Spine Institute Pc v. Auto-Owners Insurance Co
354765
| Mich. Ct. App. | Sep 2, 2021Background
- Michigan Head & Spine Institute (plaintiff) sued Auto-Owners and Home-Owners Insurance (defendants) under Michigan no-fault law to recover benefits for services provided to 39 separate patients.
- The complaint aggregated all 39 patient claims and asserted circuit-court jurisdiction on the ground that the amount in controversy exceeded $25,000, but the prayer for relief did not specify any dollar amount.
- The majority opinion treated the provider as a single plaintiff able to aggregate its multiple claims to satisfy the circuit-court jurisdictional minimum.
- Judge Riordan dissented, arguing the provider’s claims are derivative of individual patients’ claims and therefore the provider cannot aggregate unrelated patient claims to meet the jurisdictional threshold.
- The dissent relies on Moody and Boyd to argue that, in the no-fault context, amount-in-controversy is determined with respect to a single patient’s claim and that aggregation of separate patients’ claims is barred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held (dissent) |
|---|---|---|---|
| May a single healthcare provider aggregate separate patients’ no-fault claims to meet circuit-court jurisdiction? | Provider: as a single plaintiff, it may aggregate multiple claims against insurers to reach >$25,000. | Defendants: aggregation of unrelated patient claims is impermissible because each patient’s claim is distinct. | Provider cannot aggregate multiple patients’ claims; such aggregation equates to joining separate plaintiffs and fails Boyd/Moody. |
| Does the plaintiff’s prayer for relief control amount in controversy? | Provider: the complaint’s allegations (including jurisdictional statement) suffice to show >$25,000. | Defendants: prayer controls under Hodge; absent a dollar amount in the prayer, jurisdiction is questionable. | Prayer controls; because the prayer did not state an amount, the complaint fails to establish circuit-court jurisdiction. |
| Are a healthcare provider’s claims derivative of patients’ claims in no-fault actions? | Provider: has a direct claim against insurer (post‑2019 amendment) and may assert consolidated claims. | Defendants: provider’s claims remain derivative of patients’ underlying rights; aggregation still improper. | Provider’s claims are derivative; Moody’s view that provider is effectively multiple plaintiffs remains applicable. |
| Do Covenant (2017) and the 2019 amendment change the aggregation analysis? | Provider: statutory amendment restoring direct provider suits permits aggregation. | Defendants: amendment restored direct suits but did not eliminate derivative nature of provider claims for aggregation analysis. | Amendment revives direct suits but does not authorize aggregation of multiple patients’ separate claims to establish jurisdiction. |
Key Cases Cited
- Hodge v State Farm Mut Auto Ins Co, 499 Mich 211 (Mich. 2016) (amount in controversy for jurisdictional inquiry is determined from the prayer for relief).
- Moody v Home Owners Ins Co, 304 Mich App 415 (Mich. Ct. App. 2014) (in no-fault cases a provider’s claims are derivative of a patient’s claim; consolidation/aggregation depends on single-patient analysis).
- Boyd v Nelson Credit Ctrs, 132 Mich App 774 (Mich. Ct. App. 1984) (a single plaintiff may aggregate multiple claims against one defendant, but aggregation of separate plaintiffs’ claims is not permitted).
- Covenant Med Ctr, Inc v State Farm Mut Auto Ins Co, 500 Mich 191 (Mich. 2017) (healthcare providers do not have an inherent statutory right to directly sue no-fault insurers absent legislative authorization).
- Regents of the Univ of Mich v State Farm Mut Ins Co, 250 Mich App 719 (Mich. Ct. App. 2002) (discusses providers’ derivative and direct claims for personal protection insurance benefits).