ZCD Transportation, Inc. v. State Farm Mutual Automobile Insurance, 830 N.W.2d 428

Grinblatt, injured in 2001 automobile accident, used a mobility scooter and a van with lift/hand controls for mobility.
Post-accident, Grinblatt was too weak to transfer between scooter and van, so plaintiff provided transportation for medical appointments and personal trips.
Plaintiff billed three charges: pick-up fee $35, wait fee $30/hour in 15-minute increments, and mileage with a $3/mile rate and minimum miles (10 one-way, 20 round trip).
Most Grinblatt trips were under the mileage minimum, and plaintiff acknowledged the service included personal, non-medical transportation as a courtesy.
State Farm objected to reimbursement for non-medical personal trips and for costs when Grinblatt was not in the vehicle; trial court granted summary disposition for defendant.
On appeal, the court reviews a 2.116(C)(10) motion de novo and analyzes whether expenses are causally connected to the accident and are reasonably necessary and reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are non-medical transportation expenses recoverable?	Grinblatt injury-related transportation may include replacement or care-related services.	Non-medical personal trips are replacement services, not allowable expenses.	Non-medical transportation is not recoverable as an allowable expense.
Are mileage charges and minimum-mileage rules reasonable and incurred?	Miles billed reflect actual transportation and related costs.	Some miles billed exceeded actual distance; charges may be unreasonable.	Mileage beyond actual miles is not payable; reasonableness and incurred status require factual review.
Are pick-up and wait-time charges reasonably necessary and incurred?	Pick-up and wait times are necessary to transport to medical care.	No evidence of reasonableness; issue not addressed by parties.	Reasonableness of pick-up and wait-time charges is a factual question to be decided.
Must expenses be causally connected to the insured's injury to be payable?	Costs linked to care/recovery may be payable if reasonably necessary.	Only expenses tied to injury-related care and rehabilitation are payable.	Expenses must be causally connected to the injury and relate to care/recovery or rehabilitation.

Griffith v State Farm Mut Auto Ins Co, 472 Mich 521 (2005) (allowable expenses must be causally connected to injury)
Douglas v Allstate Ins Co, 492 Mich 241 (2012) (care includes services related to injury; replacement services distinguished)
Johnson v Recca, 492 Mich 169 (2012) (separate categories: allowable expenses and replacement services)
Krohn v Home-Owners Ins Co, 490 Mich 145 (2011) (reasonably necessary standard for expenses)
Proudfoot v State Farm Mut Ins Co, 469 Mich 476 (2003) (necessity and reasonableness of services)
Moghis v Citizens Ins Co of America, 187 Mich App 245 (1991) (incurred evidence required for payment)
Davis v Citizens Ins Co of America, 195 Mich App 323 (1992) (transportation costs for medical appointments allowable)
Neumann v State Farm Mut Auto Ins Co, 180 Mich App 479 (1989) (medical transportation costs recognized, subject to reasonableness)
Spiek v Dep’t of Transp, 456 Mich 331 (1998) (no-fault standard and evidentiary evaluation for summary disposition)
In re Geror, 286 Mich App 132 (2009) (no-fault expenses are legal questions reviewed de novo)
Moser v Detroit, 284 Mich App 536 (2009) (de novo review of summary disposition standard)