Copeland v. Allstate Property & Casualty Insurance Co. (March 16, 2026) (Domicile and Homelessness)
Michigan Court of Appeals decision addressing domicile and priority under the No-Fault Act.
The Michigan Court of Appeals held that domicile cannot be assigned by default merely because a claimant lacks an alternative residence, including in cases involving homelessness or transience. The Court rejected assigning domicile to a last known household based solely on the absence of a fixed residence for purposes of no-fault priority.
Instead, domicile must be determined under the Workman/Dairyland framework based on objective evidence of actual living arrangements and intent. Where the evidence does not definitively establish a single domicile, the issue remains a question of fact for the jury and is not appropriate for summary disposition.
This decision makes clear that priority disputes involving transient or homeless claimants will often turn on fact-intensive inquiries, limiting early resolution and increasing exposure in no-fault cases, until the legislature or higher court reviews the matter.
Michigan Court of Appeals decision addressing domicile and priority under the No-Fault Act.
The Michigan Court of Appeals held that domicile cannot be assigned by default merely because a claimant lacks an alternative residence, including in cases involving homelessness or transience. The Court rejected assigning domicile to a last known household based solely on the absence of a fixed residence for purposes of no-fault priority.
Instead, domicile must be determined under the Workman/Dairyland framework based on objective evidence of actual living arrangements and intent. Where the evidence does not definitively establish a single domicile, the issue remains a question of fact for the jury and is not appropriate for summary disposition.
This decision makes clear that priority disputes involving transient or homeless claimants will often turn on fact-intensive inquiries, limiting early resolution and increasing exposure in no-fault cases, until the legislature or higher court reviews the matter.
| michigan-no-fault-domicile-copeland-v-allstate-transient-claimants-2026.pdf.pdf |