Michigan Court Creates New Pip Subrogation Opportunity: Call v. L & KJ Enterprises, LLC, ___ N.W.3d ___ (Mich. App. 2026) (Docket No. 366229)
For decades, Michigan no-fault carriers operated under a rigid, confusing, and often frustrating limitation: recovery of Personal Injury Protection (PIP) benefits was largely confined to the narrow statutory framework of M.C.L.A. § 500.3116. That statute carefully circumscribes when a carrier may obtain reimbursement of a lien against its insured’s tort recovery, and Michigan courts historically…






