Spectrum Health Hospitals v. Farm Bureau Mutual Ins Co of Michigan, 492 Mich. 503

The Court grants leave to decide whether a person injured while using a vehicle taken contrary to owner prohibition may recover PIP benefits under MCL 500.3113(a).
MCL 500.3113(a) bars PIP if the user took the vehicle unlawfully unless the user reasonably believed they were entitled to take and use it.
Spectrum Health: claimant Craig Jr. used his father’s vehicle despite express prohibition by the owner’s express instruction; the intermediate user allegedly allowed by the owner’s agent; dispute over whether this constitutes an unlawful taking.
Progressive Marathon: Ryan DeYoung, an excluded driver, used his wife Nicole’s vehicle despite standing prohibition; insurer denied PIP on unlawful-taking grounds; issues framed around the family-joyriding theory.
Lower courts had applied two theories: Bronson’s chain-of-permissive-use and Priesman’s family-joyriding exception, which the Supreme Court overrules in this decision.
Court holds that taking a vehicle contrary to Michigan Penal Code joyriding statutes (MCL 750.413, 750.414) is an unlawful taking, and the phrase “a person” in MCL 500.3113(a) includes family members who take unlawfully.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does unlawful taking under MCL 500.3113(a) include joyriding?	Spectrum Health argues end user can be lawful via permissive-use chain.	Farm Bureau contends joyriding statutes define unlawfulness; chain-of-permissive-use not allowed.	Unlawful taking includes joyriding; PIP excluded.
Should Bronson's chain-of-permissive-use theory be applied to determine unlawfulness?	Spectrum Health relies on Bronson to shield the end user.	Bronson misapplies owner’s liability concepts to no-fault; inconsistent with text.	Bronson overruled; chain-of-permissive-use rejected.
Does the family-joyride exception apply to deny exclusion to a family member joyriding?	Progressive relies on Priesman’s family-joyride rationale to avoid exclusion.	No textual basis to extend a family-joyride exception to MCL 500.3113(a).	Family-joyride exception is rejected; does not apply.

Bronson Methodist Hosp v Forshee, 198 Mich App 617 (1993) (chain-of-permissive-use theory rejected here as inconsistent with no-fault text)
Spectrum Health Hosps v Farm Bureau Mut Ins Co of Mich, 490 Mich 869 (2011) (no-fault interpretation of unlawful taking; uses cited unpublished opinion in reasoning)
Priesman v Meridian Mut Ins Co, 441 Mich 60 (1992) (origin of family-joyriding discussion and UMVARA comparison)
Butterworth Hosp v Farm Bureau Ins Co, 225 Mich App 244 (1997) (courts extended joyriding reasoning prior to overrule)
Mester v State Farm Mut Ins Co, 235 Mich App 84 (1999) (reaffirmed family-joyriding rationale in Court of Appeals)
Allen v State Farm Mut Auto Ins Co, 268 Mich App 342 (2005) (confirms household-relative scope of prior approaches)
Roberts v Titan Ins Co (On Reconsideration), 282 Mich App 339 (2009) (expands family-joyriding through non-traditional family links)
Cowan v Strecker, 394 Mich 110 (1975) (owner-consent concept used to analogize no-fault consent issues)
Fout v Dietz, 401 Mich 403 (1977) (evidence to rebut implied owner consent exception discussed)
Jarrad v Integon Nat’l Ins Co, 472 Mich 207 (2005) (statutory interpretation and model acts discussion)
Spencer v Hartford Accident & Indemnity Co, 179 Mich App 389 (1989) (model act interpretation context cited in no-fault analysis)