Michigan Head & Spine Institute Pc v. Auto-Owners Insurance Co
354765
| Mich. Ct. App. | Sep 2, 2021Background:
- Michigan Head & Spine (plaintiff) provided healthcare to 39 auto-accident patients between June 11, 2019 and May 8, 2020 and sought PIP no-fault payments from Auto-Owners and Home-Owners (defendants).
- Plaintiff alleged unpaid balances exceeding $200,000 and pleaded that the amount in controversy exceeded $25,000, invoking circuit court jurisdiction.
- Defendants moved for summary disposition, arguing the 39 claims were separate (different patients, dates, treatments, insurers) and could not be aggregated to reach the $25,000 circuit-court threshold; they also advanced various substantive reasons for nonpayment (billing rates, unrelated care, insufficient invoices, alleged double billing).
- The trial court granted the motion and dismissed all claims for lack of subject-matter jurisdiction, relying on Boyd and an unpublished decision (Priority Patient).
- The Court of Appeals reversed, holding that (1) under Hodge the amount in controversy is measured by the pleading's prayer absent bad faith and (2) under Boyd a single plaintiff may aggregate multiple claims to meet the jurisdictional threshold; the case was remanded for further proceedings.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a single plaintiff can aggregate multiple claims (for different patients) to meet the $25,000 circuit-court threshold | Yes — Michigan Head & Spine is a single plaintiff and may aggregate its claims | No — claims arise from separate patients and insurers and cannot be aggregated to reach jurisdictional amount | Reversed: single plaintiff may aggregate its claims under Boyd; Hodge governs amount-in-controversy by the pleading's prayer |
| How to determine the amount in controversy | Use the amount prayed in the complaint | Should assess claims individually; aggregation here is improper | Hodge controls: amount in controversy is determined from the pleading's prayer absent bad faith |
| Precedent relied on by defendants (Priority Patient / Boyd) | N/A | Priority Patient and Boyd support refusing aggregation | Boyd permits aggregation by one plaintiff; Priority Patient (unpublished) was found unpersuasive and not followed |
| Proper procedural rule for the dismissal motion and standard of review | Circuit court had jurisdiction; dismissal improper | Moved under MCR 2.116(C)(8)/(C)(10); dismissal appropriate for lack of jurisdiction | Court treated motion as MCR 2.116(C)(4) (jurisdictional); reviewed de novo and found dismissal erroneous |
Key Cases Cited
- Hodge v. State Farm Mut. Auto. Ins. Co., 499 Mich. 211, 884 N.W.2d 238 (Mich. 2016) (amount in controversy is determined from the pleading's prayer absent bad faith)
- Boyd v. Nelson Credit Ctrs., 132 Mich. App. 774, 348 N.W.2d 25 (Mich. Ct. App. 1984) (a single plaintiff may aggregate multiple claims to reach jurisdictional amount)
- Moody v. Home Owners Ins. Co., 304 Mich. App. 415, 849 N.W.2d 31 (Mich. Ct. App. 2014) (discusses aggregation/amount-in-controversy principles applied in lower courts)