Wyoming Chiropractic Health Clinic Pc v. Auto-Owners Ins Company
308 Mich. App. 389
| Mich. Ct. App. | 2014Background
- Wyoming Chiropractic Health Clinic sued Auto-Owners for unpaid personal protection insurance (PIP) benefits for treatment provided to insureds Mary Catoni and Kalem Rowe‑Catoni.
- Auto‑Owners moved for summary disposition asserting Wyoming Chiropractic lacked standing/statutory authority to sue under the Michigan no‑fault act.
- The trial court denied the motion; Auto‑Owners appealed.
- The appeal raised pure questions of law: whether a healthcare provider is a real party in interest/statutorily entitled to bring a direct claim for PIP benefits under MCL 500.3112.
- The Court of Appeals reviewed de novo, considering prior Michigan appellate decisions interpreting MCL 500.3112 and the scope of provider claims under the no‑fault act.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a healthcare provider has statutory standing to sue an insurer for PIP benefits under MCL 500.3112 | Wyoming Chiropractic: MCL 500.3112 allows payment "to or for the benefit of" an injured person; providers who submit claims do so "for the benefit of" insureds and thus have a direct cause of action | Auto‑Owners: The no‑fault statute confines benefits to injured persons/dependents; provider suits amount to improper assignments or derivative claims barred by the statute | Court: Providers have an independent, direct cause of action for PIP benefits when they seek payment "for the benefit of" an insured; summary disposition denied |
| Whether this action is barred by prior precedent forbidding assignments of no‑fault benefits | Wyoming Chiropractic: Not an assignment of future rights; it seeks direct reimbursement for services rendered, consistent with Munson/Lakeland/Regents | Auto‑Owners: Cites Starkey and other cases to argue assignments/nonassignability bar provider suits | Court: Distinguished Starkey and similar authorities; held those decisions do not preclude provider standing as interpreted in later appellate decisions |
| Whether allowing provider suits conflicts with public policy or creates undue burdens on insurers | Wyoming Chiropractic: Provider suits serve no‑fault goals—prompt, adequate, equitable payment—and expedite recovery when insureds do not sue | Auto‑Owners: Permitting provider suits increases multiplicity of actions and insurer exposure to penalties/interest | Court: Legislative language of MCL 500.3112 resolves policy concerns; permitting provider suits furthers no‑fault remedial goals |
| Proper procedural basis for dismissal (real‑party‑in‑interest/jurisdiction) | Wyoming Chiropractic: Complaint pleads direct cause of action; pleadings sufficient to defeat (C)(8) dismissal | Auto‑Owners: Argued lack of subject‑matter jurisdiction/statutory standing under MCR 2.116(C)(4) and real‑party‑in‑interest under (C)(8)/(C)(10) | Court: Review under (C)(8) appropriate (based on pleadings); held plaintiff’s pleadings state an enforceable claim so dismissal improper |
Key Cases Cited
- Munson Medical Center v. Auto Club Ins. Ass'n, 218 Mich. App. 375 (healthcare providers have a right to be paid no‑fault medical expenses)
- Lakeland Neurocare Centers v. State Farm Mut. Auto. Ins. Co., 250 Mich. App. 35 (provider claims "for the benefit of" insureds create direct causes of action; providers may enforce penalty/interest provisions)
- Regents of Univ. of Mich. v. State Farm Mut. Ins. Co., 482 Mich. 946 (affirming that hospitals/providers have direct claims for PIP benefits)
- Borgess Medical Center v. Resto, 273 Mich. App. 558 (recognizing providers as claimants entitled to seek penalty interest and attorney fees)
- Aetna Cas. & Surety Co. v. Starkey, 116 Mich. App. 640 (assignment of future no‑fault benefits held void under nonassignability provision; distinguished)
- Belcher v. Aetna Cas. & Surety Co., 409 Mich. 231 (PIP benefits payable to injured persons/dependents; not dispositive on provider claims)