Farm Bureau required to respond to insureds' PIP claims

Thomas and Jason Grant were waiting to make a left turn when they  were rear-ended by a truck.  The Grants were insured for Personal Injury Protection (PIP) benefits and UIM (Underinsured Motorist Coverage) by Farm Bureau.  They filed an action against the at-fault and Farm Bureau, seeking PIP benefits and non-economic damages.  In response to a motion by Farm Bureau, the Court dismissed their claim in its entirety.  It held that they had no proved a "serious impairment of bodily function" and Farm Bureau successfully argued that the two men had suffered no related medical expenses.

On appeal, the unanimous Court of Appeals panel noted that the parties had resolved the third-party claim for third-party or UIM benefits and reversed the summary disposition of PIP benefits.  The Court noted that Farm Bureau had not adequately supported its claim for summary disposition and that the Court had mis-applied the law in concluding that the two men could not have suffered any injury justifying payment of PIP benefits.