Michigan court says bobtail insurers cannot restrict mandatory coverage to listed vehicles, ruling protection follows people not autos.
The Michigan Court of Appeals on February 18, 2026 reversed a lower court decision that had favored Acceptance Indemnity Insurance Company, ruling that the insurer's bobtail policy language conflicted with state law requiring personal injury protection coverage to follow the person named in the policy, not just particular vehicles.
The case centers on Termaine Turner, who owned a 2008 Peterbilt tractor he used for work. Turner had purchased a non-trucking liability policy from Acceptance, the type of coverage truckers typically buy to protect themselves when driving their rig without cargo or a trailer for personal use.
When Turner was injured in a May 2021 accident in Las Vegas while driving a friend's Nissan Altima, he sought coverage from Acceptance after his other insurer had already canceled his policy for non-payment. Acceptance refused, pointing to policy language that limited coverage to the Peterbilt tractor listed on the certificate of insurance.
The certificate stated that coverages, including personal injury protection, applied only to specified autos listed in the policy. Since Turner was driving the Nissan when the accident occurred, Acceptance argued the policy simply did not cover him.
A trial court agreed with the insurer, reasoning that Turner had purchased a specific, limited policy that provided coverage only when he drove the tractor for non-business purposes. The court noted that Turner was supposed to have gotten coverage from his other insurer but had let that policy lapse.
The appeals court saw things differently. Writing for a three-judge panel, the court pointed to Michigan's no-fault insurance law, which makes personal injury protection coverage mandatory and ties that coverage to people rather than vehicles. The relevant statute says coverage applies to accidental bodily injury to the person named in the policy if the injury arises from a motor vehicle accident.
The court relied heavily on a 2022 decision involving Hartford Accident & Indemnity Company, where it had ruled that an insurer could not avoid statutory requirements by designating specific vehicles for coverage instead of covering the named insured. In that case, a business owner was injured when a vehicle fell on him while he was servicing it, and his commercial auto insurer tried to deny coverage because the policy only covered specifically identified vehicles.
The appeals court found Turner's situation nearly identical. While Acceptance had sold him a bobtail policy with inherent limitations on when and how the tractor could be used, the insurer had still included personal injury protection coverage in the policy. Once that coverage was included, Michigan law dictated how it had to work.
The court acknowledged that Acceptance had tried to distinguish Turner's case from the Hartford decision by citing an earlier unpublished opinion involving similar policy language. In that case, decided in 2022, the court had allowed an insurer to deny coverage under a bobtail policy when the accident did not involve the listed vehicle. But the appeals court noted that decision came before the published Hartford ruling, and under Michigan court rules, published opinions control over unpublished ones.
More importantly, the court said, the plaintiff in that earlier case had coverage available through another policy, while Turner had no other source of personal injury protection benefits available to him.
The court also rejected Acceptance's argument that insurers can choose to sell policies with only optional coverages and skip the mandatory ones entirely. While that might be true in theory, the court said, Acceptance had actually sold Turner a policy that included personal injury protection coverage. Having done so, the insurer could not then limit that mandatory coverage in ways that conflicted with state law.
The decision means Acceptance will have to reform its policy to comply with statutory requirements. The case has been sent back to the trial court for further proceedings.
For insurers writing commercial auto policies, particularly bobtail coverage for truck drivers, the decision reinforces that Michigan law treats personal injury protection as person-based rather than vehicle-based coverage. Even in specialized commercial policies with limited scope, insurers cannot use policy language to restrict mandatory coverages to specific vehicles when state law requires coverage to follow the named insured across different vehicles.
The ruling may prompt insurers to review their bobtail policy language and coverage structures to ensure compliance with the principle that mandatory personal injury protection coverage attaches to people, not just the vehicles listed on a certificate of insurance.
