Michigan Court of Appeals Clarifies Constructive Ownership Under the No-Fault Act
Davis v Baldini, Michigan Court of Appeals (March 10, 2026)
The Michigan Court of Appeals recently clarified how courts should analyze constructive ownership of a motor vehicle under Michigan’s No-Fault Act, MCL 500.3101.
The Court emphasized that ownership under the statute requires proprietary or possessory use consistent with concepts of ownership for more than 30 days, not merely regular or incidental use of another person’s vehicle. The inquiry focuses on whether the driver exercised control and personal use resembling ownership, rather than limited use with permission.
The Court reversed the trial court’s grant of summary disposition after concluding that the record permitted competing inferences about the nature of the plaintiff’s vehicle use. Although the plaintiff regularly drove her daughter to and from work, the evidence also suggested that the use was limited to facilitating the daughter’s commute and did not include personal errands, commuting, or other ownership-like control.
Because the evidence could support either incidental use or proprietary use, the Court held that a genuine issue of material fact existed regarding constructive ownership, making summary disposition improper.
The decision reinforces that constructive ownership under the No-Fault Act is a fact-intensive inquiry. Regular use of a vehicle does not automatically render a driver an “owner” for purposes of the uninsured-owner bar under MCL 500.3135(2)(c). Courts must examine the nature, scope, and purpose of the vehicle’s use before applying the statutory bar to tort recovery.
Davis v Baldini, Michigan Court of Appeals (March 10, 2026)
The Michigan Court of Appeals recently clarified how courts should analyze constructive ownership of a motor vehicle under Michigan’s No-Fault Act, MCL 500.3101.
The Court emphasized that ownership under the statute requires proprietary or possessory use consistent with concepts of ownership for more than 30 days, not merely regular or incidental use of another person’s vehicle. The inquiry focuses on whether the driver exercised control and personal use resembling ownership, rather than limited use with permission.
The Court reversed the trial court’s grant of summary disposition after concluding that the record permitted competing inferences about the nature of the plaintiff’s vehicle use. Although the plaintiff regularly drove her daughter to and from work, the evidence also suggested that the use was limited to facilitating the daughter’s commute and did not include personal errands, commuting, or other ownership-like control.
Because the evidence could support either incidental use or proprietary use, the Court held that a genuine issue of material fact existed regarding constructive ownership, making summary disposition improper.
The decision reinforces that constructive ownership under the No-Fault Act is a fact-intensive inquiry. Regular use of a vehicle does not automatically render a driver an “owner” for purposes of the uninsured-owner bar under MCL 500.3135(2)(c). Courts must examine the nature, scope, and purpose of the vehicle’s use before applying the statutory bar to tort recovery.
| michigan-no-fault-constructive-ownership-davis-v-baldini-2026.pdf.pdf |