Scott Eickhoff v. Farm Bureau General Insurance Co of Mi, 330671

Plaintiff was injured after being ejected from a bucket attached to a boom permanently mounted on his parked work truck when a cable snapped while he was trimming trees.
Before the accident plaintiff had parked the truck, set the emergency brake, put it in first gear, and deployed downriggers that slightly lifted the suspension but left the tires on the ground.
Plaintiff injured both arms and his right hand and sought first-party no-fault (PIP) benefits.
Defendant insurer denied benefits, arguing the truck was not being used “as a motor vehicle” at the time of injury and thus coverage under MCL 500.3105(1) and the parked-vehicle rules of MCL 500.3106(1) did not apply.
The trial court granted defendant’s MCR 2.116(C)(10) summary-disposition motion, citing factual similarity to Minch (an unpublished Court of Appeals decision).
On appeal the Court of Appeals affirmed, concluding plaintiff’s truck was being used as a foundation for tree‑trimming equipment rather than for its transportational function, so no coverage was triggered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff’s injury arose out of the use of a parked motor vehicle "as a motor vehicle" for transportational purposes under MCL 500.3105(1) (and thus whether an exception in MCL 500.3106(1) can provide coverage).	Eickhoff: the injury involved direct contact with equipment permanently mounted on the vehicle, so MCL 500.3106(1)(b) applies and PIP benefits are available.	Farm Bureau: the truck was being used as a stationary foundation for tree‑trimming equipment, not for its transportational function, so McKenzie’s “transportational function” test bars coverage.	Court affirmed summary disposition for defendant: the truck lacked the requisite transportational use at the time of injury; coverage under MCL 500.3105(1) therefore not triggered.

McKenzie v. Auto Club Ins. Ass'n, 458 Mich 214 (Legislature intended coverage only when vehicle use is closely related to transportational function)
Drake v. Citizens Ins. Co. of Am., 270 Mich App 22 (equipment use may be related to transportational function when vehicle is immediately drivable and unloading is part of delivery)
Miller v. Auto-Owners Ins. Co., 411 Mich 633 (injuries involving parked vehicles do not normally involve the vehicle as a motor vehicle)
Rice v. Auto Club Ins. Ass'n, 252 Mich App 25 (parked vehicle’s transportational function can be unrelated to the accident)
Putkamer v. Transamerica Ins. Corp. of Am., 454 Mich 626 (whether injury arises out of vehicle use is a legal question when facts are undisputed)