Ez Minor v. State Farm Mutual Automobile Insurance Company

CourtMichigan Court of Appeals
DecidedOctober 1, 2025
Docket371060
StatusUnpublished

This text of Ez Minor v. State Farm Mutual Automobile Insurance Company (Ez Minor v. State Farm Mutual Automobile Insurance Company) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ez Minor v. State Farm Mutual Automobile Insurance Company, (Mich. Ct. App. 2025).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

EZ MINOR, by Next Friends RICHARD HILLIKER UNPUBLISHED and ALEXIS ZINK, October 01, 2025 9:56 AM Plaintiffs-Appellees, and

VHS OF MICHIGAN, INC., doing business as DETROIT MEDICAL CENTER, and REGENTS OF THE UNIVERSITY OF MICHIGAN,

Intervening Plaintiffs-Appellees,

v No. 371060 Wayne Circuit Court STATE FARM MUTUAL AUTOMOBILE LC No. 22-010532-NF INSURANCE COMPANY,

Defendant-Appellant, and

FARMERS INSURANCE EXCHANGE,

Defendant-Appellee.

Before: GADOLA, C.J., and MARIANI and TREBILCOCK, JJ.

PER CURIAM.

This no-fault action arises from catastrophic injuries EZ, a young child, sustained in a car accident while a passenger in a vehicle owned and driven by her maternal grandmother. At the time of the accident, EZ’s mother did not have an automobile insurance policy, but EZ’s maternal grandmother had one with defendant State Farm Mutual Automobile Insurance Company. At issue in this appeal is whether EZ was domiciled at her maternal grandmother’s home or named in the applicable insurance policy when the accident occurred, such that EZ was eligible to recover

-1- personal protection insurance (“PIP”) benefits from State Farm under the no-fault act, MCL 500.3101 et seq. In response to the parties’ competing motions for summary disposition below, the trial court answered this question in the affirmative, finding State Farm to be the highest- priority insurer. For the reasons set forth in this opinion, we reverse and remand for further proceedings.

I. BACKGROUND

A. FACTUAL BACKGROUND

EZ’s maternal grandmother, Candice Renee Reeves (“Reeves”), lived in a house in Capac, Michigan (the “Capac Address”).1 Reeves’s daughter, Alexis Zink (“Zink”)—who is EZ’s mother—also lived at the Capac Address for much of her life. Immediately after giving birth to EZ in 2020, however, Zink moved into a house in Yale, Michigan (the “Yale Address”). Zink rented the Yale Address from her grandparents, who specifically bought it as a place for Zink and EZ to live. Although Zink’s grandparents charged rent, there was no formal rental agreement between them, and they were lenient when she failed to pay.

When the accident occurred in 2022, Reeves lived at the Capac Address with her husband and their two other children. Zink, EZ, and EZ’s father—Richard Hilliker (“Hilliker”)—lived at the Yale Address.2 However, Zink’s relationship with Hilliker had “been going downhill” in the six months preceding the accident, and Zink had been “trying to come up with a game plan and get things all in order” so that she and EZ “could leave or figure something else out.” As part of this plan, Zink intended to move back to the Capac Address permanently. Zink and EZ thus began “transitioning” to the Capac Address sometime around December 2021, including moving some belongings there. Accordingly, Zink described the Yale Address as the one where she and EZ “currently resided” when the accident occurred but “not the [address] that [they] had intended to be in.”

Zink and EZ “both had a lot of stuff” at the Capac Address before the accident. For example, EZ’s designated bedroom there contained a crib and a small bed; dressers; clothes; toys and “blankies”; and supplies such as diapers, bottles, formula, wipes, and pacifiers. For her part, Zink had clothes and “all [her] care stuff” there, and she was gradually starting to take over other items and “working on moving things slowly.” Though it is unclear whether Zink slept in EZ’s room when they stayed at the Capac Address, she kept her belongings—most of which she moved from the Yale Address’s garage—in EZ’s room and the basement. In addition to having belongings at the Capac Address, Zink generally claimed she received “some” bills and other mail there before the accident. However, she could not provide specific details regarding the source of this mail or why she received it there.

1 The police report of the accident indicates Reeves lived in Mussey, Michigan. According to Reeves and Zink, Capac and Mussey refer to the same city and are used interchangeably. 2 Though Zink and Hilliker never married, and no formal custody order was in place when the accident occurred, Zink always “had custody” of EZ.

-2- The utilities at the Yale Address were in Zink’s name, but Hilliker and Reeves helped her pay for them. Hilliker also helped Zink pay the rent. More generally, although Zink generally worked, she and EZ were “dependent on” Hilliker’s and Reeves’s financial support. Zink also relied on Reeves for other forms of support, such as transportation and child care. According to Zink, Reeves had EZ in her care and custody “[p]retty much daily” before the accident, and would “sometimes” have EZ “for almost a week at a time.” Zink also spent the night at the Capac Address “numerous times” each week in the months preceding the accident, though she could not recall the exact number of days.

B. PROCEDURAL HISTORY

In September 2022, Zink and Hilliker, as next friends of EZ (collectively, “plaintiffs”), instituted this action by filing a complaint against State Farm and the Michigan Automobile Insurance Placement Facility (“MAIPF”), seeking payment of first-party no-fault benefits. The following month, Zink filed an application for PIP benefits with the MAIPF on EZ’s behalf. The trial court later entered a stipulated order substituting defendant Farmers Insurance Exchange (“Farmers”) in place of the MAIPF. Intervening plaintiff VHS of Michigan, Inc., doing business as Detroit Medical Center (“DMC”), eventually filed an intervening complaint seeking repayment from either State Farm or Farmers for certain medical services it provided EZ.

Ultimately, Farmers, DMC, plaintiffs, and State Farm each moved for summary disposition under MCR 2.116(C)(10). Through those motions, the parties disputed, in pertinent part, (1) whether DMC and plaintiff could maintain claims against Farmers, and (2) whether there was a genuine issue of material fact that EZ was domiciled with Reeves at the Capac Address when the accident occurred, such that State Farm was the highest-priority insurer responsible for the payment of EZ’s no-fault claims. After the parties filed their motions for summary disposition and responsive pleadings, intervening plaintiff Regents of the University of Michigan (“Regents” and, together with DMC, “intervening plaintiffs”) filed an intervening complaint seeking reimbursement from State Farm or Farmers for medical services provided to EZ.

At the hearing on the summary-disposition motions, the trial court analyzed each of the domicile factors set forth in Workman v Detroit Auto Inter-Ins Exch, 404 Mich 477; 274 NW2d 373 (1979), and Dairyland Ins Co v Auto Owners Ins Co, 123 Mich App 675; 333 NW2d 322 (1983), and found that all but two weighed in favor of Zink, and thus EZ, being domiciled at the Capac Address at the time of the accident. Additionally, the trial court expressed its apparent belief that State Farm failed to meet the burden of supporting its motion for summary disposition. So it entered orders, in relevant part: (1) denying State Farm’s motion for summary disposition as to plaintiffs’ and intervening plaintiffs’ claims; (2) granting plaintiffs’ motion for summary disposition; (3) granting Farmers’s motion for summary disposition and dismissing it as a party; and (4) granting DMC’s motion for partial summary disposition. After State Farm unsuccessfully moved for reconsideration,3 it filed an application for leave to appeal in this Court, which this

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Related

Maiden v. Rozwood
597 N.W.2d 817 (Michigan Supreme Court, 1999)
Workman v. Detroit Automobile Inter-Insurance Exchange
274 N.W.2d 373 (Michigan Supreme Court, 1979)
Dairyland Insurance v. Auto-Owners Insurance
333 N.W.2d 322 (Michigan Court of Appeals, 1983)
Cervantes v. Farm Bureau General Insurance
726 N.W.2d 73 (Michigan Court of Appeals, 2007)
Grange Insurance Co of Michigan v. Edward Lawrence
494 Mich. 475 (Michigan Supreme Court, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Ez Minor v. State Farm Mutual Automobile Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ez-minor-v-state-farm-mutual-automobile-insurance-company-michctapp-2025.