A Michigan appeals court just told insurers that a policyholder's word on a PIP opt-out form is not enough.
In a decision dated March 25, 2026, the Michigan Court of Appeals reversed a lower court ruling, finding that Allstate could not enforce a PIP medical coverage opt-out when the statutory conditions for that opt-out had not actually been met. The result is that the policy must be treated as providing unlimited PIP medical coverage - a potentially costly outcome for the insurer.
The case arose from a February 2023 car accident involving Dwight Turner and his mother, Jacqueline Springer. Turner was injured and received treatment at Northland Radiology's facility over the course of roughly a year. He did not carry his own auto insurance policy and purportedly had healthcare coverage through Medicaid.
Springer held a no-fault auto insurance policy with Allstate. When she renewed the policy in September 2022, she opted out of PIP medical coverage entirely in exchange for a 100% premium reduction. The opt-out form required her to certify two things: that she had coverage under both Medicare Parts A and B, and that any spouse and all resident relatives either had qualified health coverage or were covered under another auto policy with PIP medical coverage.
Springer did have Medicare Parts A and B and provided proof. But she did not identify Turner as a resident relative on the form, nor did she provide proof that he had qualified health coverage. Under Michigan law, Medicaid does not count as qualified health coverage for purposes of the PIP opt-out.
When Northland Radiology sought payment from Allstate for Turner's treatment, the insurer argued it owed nothing. Springer had opted out, and Allstate said it had no reason to doubt her certification – it did not even know Turner existed. The trial court agreed, granting summary disposition to Allstate on the basis that the insurer was entitled to rely on what its policyholder had told it.
The Court of Appeals saw it differently. Under Michigan's no-fault reform, which took effect in July 2020, a named insured can opt out of PIP medical coverage only if a specific set of statutory conditions is met. These include the insured being a qualified person with Medicare Parts A and B coverage, all resident relatives having their own qualified health coverage or PIP coverage under another auto policy, and the insured providing the insurer with documentation verifying coverage for everyone in the household.
The appeals court found that not all of those conditions were satisfied here. Turner lacked qualified health coverage, and Springer had not provided documentation for him. Because the opt-out criteria were not fully met, the court concluded the election was ineffective. And under the statute, an ineffective opt-out means the policy defaults to unlimited PIP medical coverage – not just for Turner, but for the policy as a whole.
The court was careful to note that the statute applies the consequences of an opt-out election to the named insured, their spouse, resident relatives, and anyone else who would have had a right to claim PIP benefits under the policy. It reasoned that an ineffective election should carry the same scope. The Legislature, the court observed, chose to apply the unlimited coverage default to the entire policy, not to individual claimants. Had it intended a narrower result, it could have written the statute that way.
The case has been sent back to the trial court for further proceedings. The appeals court did not weigh in on whether Allstate might be able to raise a fraud defense or seek rescission of the opt-out on remand.
For insurers writing auto policies in Michigan, the decision raises a practical question that goes beyond legal theory: what responsibility does a carrier have to verify the information on a PIP opt-out form, rather than simply accepting the policyholder's certification at face value? The appeals court did not say Allstate acted in bad faith, but it made clear that good-faith reliance on an inaccurate form does not save an opt-out that fails the statutory test.
