July 14, 2026
The Court of Appeals, in an unpublished opinion titled Pineau v State Farm, discussed whether the injuries a plaintiff suffered arose out of the ownership, operation, maintenance, or use of a motor vehicle under the Michigan No-Fault Act.
In Pineau, Plaintiff sustained injuries when a firework exploded inside his vehicle while driving to work. Plaintiff provided testimony that while he attempted to place his cigarette lighter back, his vehicle wandered onto the road’s rumble strips, causing him to swerve, drop the heated lighter into the center console, and unintentionally ignite one of the fireworks that were in his vehicle. Because Plaintiff was operating the vehicle when this occurred, Plaintiff was unable to get the firework out of the vehicle before it exploded. State Farm denied Plaintiff’s claim for Personal Protection Insurance (“PIP”) benefits, arguing that the injuries resulted solely from the firework explosion and did not arise out of the ownership, operation, maintenance, or use of a motor vehicle as required under MCL 500.3105(1).
State Farm moved for summary disposition, arguing that the vehicle was merely the location to which the injury occurred and, therefore, Plaintiff’s injuries lacked the necessary causal connection to the vehicle’s transportational function. State Farm relied upon evidence that Plaintiff presented three different stories as to how his injuries occurred, two of which did not involve rumble strips or Plaintiff accidentally dropping the lighter. Plaintiff responded that his deposition testimony, which included the rumble strips story, was sufficient to create a genuine issue of material fact that the operation of the vehicle directly caused the sequence of events leading to the explosion of the firework in his hand. The trial court relied upon Plaintiff’s sworn testimony and denied summary disposition, finding Plaintiff’s testimony created a genuine issue of material fact, and the jury ultimately returned a verdict in Plaintiff’s favor.
On appeal, State Farm argued that Plaintiff’s injuries were not sufficiently related to the operation or use of a motor vehicle under MCL 500.3105(1). The Court of Appeals disagreed, viewing the conflicting evidence in the light most favorable to the non-movant Plaintiff. The Court reiterated the discussion in Thornton v Allstate Insurance Co and McKenzie v Auto Club Insurance Association, 425 Mich 643 (1986), where the Court required causal connection be more than incidental or mere “but for” causation. Rather, it must bear a sufficiently close relationship to the vehicle’s transportational function. The Court concluded that reasonable minds could find the vehicle was influential in causing the injuries because the movement of the vehicle over the rumble strips caused Plaintiff to drop the lighter, subsequently igniting the firework, and prevented him from being able to exit the vehicle before the explosion occurred.
The Court affirmed the trial court’s denial of summary disposition, denial of directed verdict, and the jury’s verdict in Plaintiff’s favor.