Michigan Head & Spine Institute, PC v. State Farm Mutual Automobile Insurance
299 Mich. App. 442
| Mich. Ct. App. | 2013Background
- Motor vehicle accident on Jan 20, 2008 involving insured Biba under defendant’s no-fault policy.
- On July 30, 2009, Biba signed a release for $35,000 discharging defendant from no-fault claims and future expenses.
- Release text broadly bars future no-fault expenses, including medical, services, and related costs.
- On Feb 26, 2010, Biba began treatment for injuries; defendant refused to pay relying on the release.
- Plaintiff filed no-fault payment, penalties, fees, and declaratory judgment claims on Dec 17, 2010; district court granted partial summary disposition for plaintiff; circuit court affirmed.
- The trial courts’ rulings interpreted the release to not bar provider recoupment, which the court ultimately reversed and remanded for entry of summary disposition in defendant’s favor.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the release bar the healthcare provider’s independent recoupment claim? | Plaintiff argues release does not bar provider recoupment under MCL 500.3112. | Defendant argues the release extinguishes all no-fault liability for future costs. | Release bars provider’s recoupment; remand for entry of judgment for defendant. |
| Does the phrase ‘or on behalf of’ indicate an independent provider claim under MCL 500.3112? | Lakeland Neurocare supports independent provider claim. | Release language shows broad discharge including provider claims. | Language indicates inclusion of provider reimbursement; not a separate right to future benefits. |
| Does the UM Health System preauthorization exception create an exception to the release? | The preauthorization provision could carve out future therapy claims. | The exception is narrow and does not cover post-release treatment. | Exception unambiguous and inapplicable; does not save provider claim. |
Key Cases Cited
- Lakeland Neurocare Centers v State Farm Mut Auto Ins Co, 250 Mich App 35 (2002) (recognizes independent provider claims under MCL 500.3112)
- Cole v Ladbroke Racing Mich, Inc., 241 Mich App 1 614 NW2d 169 (2000) (interpretation of release terms governs scope)
- Shay v Aldrich, 487 Mich 648 790 NW2d 629 (2010) (law governing release scope and intent)
- Anzaldua v Neogen Corp., 292 Mich App 626 808 NW2d 804 (2011) (standard of review for summary disposition)
- Rinke v Auto Moulding Co., 226 Mich App 432 573 NW2d 344 (1997) (release-based bar to claims)