Almost a year after the accident, Spectrum filed an "application for personal injury protection [PIP] benefits" with the MACP/MAIPF. Spectrum's agent signed as the "preparer" and the signature line for the "injured Person or Representative" was left blank. Spectrum directed the MACP/MAIPF to the police report, which indicated that the driver of the vehicle did not have no-fault insurance.

The MACP/MAIPF sent Spectrum a generic form letter denying the application, stating:

We have received the application for benefits through the [MACP], which you submitted on 08/10/2017. After careful review it has been determined that your application is ineligible for assignment under Michigan No Fault Act. If you have any questions regarding this determination please contact a representative for the [MACP], operated by the [MAIPF].

Spectrum subsequently filed suit for mandamus and declaratory relief, asserting that the MACP/MAIPF had a clear legal and ministerial duty to assign the claim to a no-fault insurer.

The MACP/MAIPF insisted that the application was invalid at its inception based on the absence of Ms. Benoit's signature as claimant.

The trial court agreed with the MACP/MAIPF and dismissed Spectrum's action. It pointed out that the plan rules required that the application be signed by the claimant or her representative and that Spectrum had not signed in that capacity.

Spectrum appealed.

The Appellate Court Decision

The appellate court reversed, rejecting the argument by the MACP/MAIPF that Spectrum's application was "obviously ineligible" for assignment because its rules mandated that Ms. Benoit or her representative sign the application.

In its decision, the appellate court explained that nothing in the no-fault act required a claimant to file a claim with the MACP/MAIPF on a form application signed by the claimant. This requirement, the appellate court said, came "entirely" from the "Michigan Assigned Claims Plan" "adopt[ed], implement[ed] and maintain[ed]" by the MAIPF.

In the appellate court's view, mandating "strict adherence to the minutiae" of its notice provisions was inconsistent with Michigan law. The appellate court noted that even with the notice provisions enacted by the legislature in the no-fault act, "substantial compliance" that fulfilled the purpose of the statute was sufficient to preserve a claim.

It then ruled that once the MAIPF received "reasonable proof" of the fact and amount of loss sustained by a claimant eligible to claim benefits as stated in MCL 500.3172(1), it had to "promptly assign the claim in accordance with the plan."

The MACP/MAIPF was tasked only with making the initial determination of eligibility of a claim and only could deny an "obviously ineligible" claim, the appellate court said – and the absence of a signature did not meet that threshold. Because Spectrum's claim was not "obviously ineligible," the MACP/MAIPF was required to assign it to a member insurer, the appellate court concluded.

The case is Spectrum Health Hospital v. Michigan Assigned Claims Plan, No. 343563 (Mich. Ct. App. Sept. 24, 2019). Attorneys involved include: For SPECTRUM HEALTH HOSPITALS, Plaintiff-Appellant: JOSEPH J. GAVIN. For MICHIGAN ASSIGNED CLAIMS PLAN, MICHIGAN AUTOMOBILE INSURANCE PLACEMENT FACILITY, JOHN DOE INSURANCE COMPANY, Defendants-Appellees: ROBERT D. STEFFES.