MICHIGAN COURT OF APPEALS (December 18, 2025) - Love v. Randolph (Docket No. 369895).
MCL 500.3114(5) under the Michigan No-Fault Act does not Require Physical Contact with a Motorcycle for Coverage to Apply according to New Michigan Court of Appeals ruling.
In Love v. Randolph, December 18, 2025, the Michigan Court of Appeals, in a published decision, clarifies motorcycle priority disputes under Michigan’s No-Fault Act, MCL 500.3114(5). Key takeaway: A motorcyclist injured in a multi-vehicle chain-reaction accident may seek PIP benefits from the insurer of a motor vehicle that actively contributed to the accident, even where that vehicle never physically contacted the motorcycle and another vehicle ultimately made impact. The Court reaffirmed that whether a vehicle is “involved in the accident” under MCL 500.3114(5) turns on a fact-intensive, causation-based analysis, not a bright-line physical-contact test, where the record supports meaningful involvement. See Love v. Randolph, 2025 Mich App LEXIS 10220.
MCL 500.3114(5) under the Michigan No-Fault Act does not Require Physical Contact with a Motorcycle for Coverage to Apply according to New Michigan Court of Appeals ruling.
In Love v. Randolph, December 18, 2025, the Michigan Court of Appeals, in a published decision, clarifies motorcycle priority disputes under Michigan’s No-Fault Act, MCL 500.3114(5). Key takeaway: A motorcyclist injured in a multi-vehicle chain-reaction accident may seek PIP benefits from the insurer of a motor vehicle that actively contributed to the accident, even where that vehicle never physically contacted the motorcycle and another vehicle ultimately made impact. The Court reaffirmed that whether a vehicle is “involved in the accident” under MCL 500.3114(5) turns on a fact-intensive, causation-based analysis, not a bright-line physical-contact test, where the record supports meaningful involvement. See Love v. Randolph, 2025 Mich App LEXIS 10220.
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