Priority Patient Transport LLC v. Farmers Insurance Exchange
329420
| Mich. Ct. App. | May 2, 2017Background
- Priority Patient Transport (plaintiff), a medical-transport provider, sued Farmers Insurance Exchange for failing to pay personal injury protection (PIP) benefits for medical transports for 14 different injured individuals.
- Plaintiff sought judgment in excess of $25,000 (plus penalties, interest, fees) in circuit court and listed the separate losses for each individual.
- Farmers moved for summary disposition under MCR 2.116(C)(4), arguing the circuit court lacked subject-matter jurisdiction because the individual PIP claims could not be aggregated to meet the $25,000 district/circuit jurisdictional threshold.
- The trial court granted summary disposition for lack of jurisdiction; plaintiff appealed, claiming it could join and aggregate the multiple PIP claims to satisfy circuit-court jurisdiction.
- The Court of Appeals reviewed de novo, examined the pleadings per Hodge, and concluded aggregation of separate injured parties’ PIP claims to reach the circuit-court jurisdictional minimum is not permitted under the circumstances presented.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff can aggregate multiple injured persons’ PIP claims to meet circuit-court jurisdictional amount | Plaintiff: may join the separate claims and aggregate them to exceed $25,000 to bring case in circuit court | Farmer: claims cannot be aggregated; jurisdiction determined from plaintiff’s single plaintiff pleadings and each claim is separate | Court: aggregation of separate injured parties’ PIP claims to obtain circuit-court jurisdiction is not permitted; circuit court lacked jurisdiction |
Key Cases Cited
- Hodge v. State Farm Mut. Auto. Ins. Co., 499 Mich 211 (Michigan Supreme Court 2016) (pleadings alone determine amount in controversy for jurisdictional inquiry)
- Boyd v. Nelson Credit Ctrs., Inc., 132 Mich App 774 (Mich. Ct. App. 1984) (multiple plaintiffs’ individual claims cannot be aggregated to meet circuit-court jurisdictional minimum)
- Moody v. Home Owners Ins. Co., 304 Mich App 415 (Mich. Ct. App. 2014) (district-court jurisdiction may be affected by consolidation/merger of claims; facts of consolidation were critical)
- Hatcher v. State Farm Mut. Auto. Ins. Co., 269 Mich App 596 (Mich. Ct. App. 2005) (right to PIP benefits belongs to the injured party)