League General Insurance v. Michigan Catastrophic Claims Ass'n

458 N.W.2d 632, 435 Mich. 338
CourtMichigan Supreme Court
DecidedJuly 16, 1990
Docket82417, (Calendar No. 6)
StatusPublished
Cited by28 cases

This text of 458 N.W.2d 632 (League General Insurance v. Michigan Catastrophic Claims Ass'n) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
League General Insurance v. Michigan Catastrophic Claims Ass'n, 458 N.W.2d 632, 435 Mich. 338 (Mich. 1990).

Opinion

Cavanagh, J.

We determine in this case whether the Michigan Catastrophic Claims Association (mcca) 1 is a state agency, and therefore subject to the Administrative Procedures Act. 2 We hold that it is not and reverse the decision of the Court of Appeals. 3

i

PACTS

The Michigan automobile no-fault act was adopted by the Legislature in 1972, 4 MCL 500.3101 et seq.; MSA 24.13101 et seq. The act requires that insurers pay or reimburse their policyholders’ lifetime medical expenses. There is no dollar limit on an insurer’s liability for medical, hospital, and rehabilitation benefits under the statute; thus, where injuries are severe, the resulting claims may be extremely high. The cost of covering an insured’s catastrophic losses — amounts of more than $250,000 — could be overwhelming to an individual insurance company.

Following implementation of the no-fault act, more insurers and reinsurers became aware of the potential for enormous liabilities under the personal protection insurance coverage provisions. Consequently, the mcca was created in 1978 5 to serve as the means for reimbursing each member *341 insurer for all "ultimate loss sustained under personal protection insurance coverages in excess of $250,000.00 in each loss occurrence.” MCL 500.3104(2); MSA 24.13104(2).

In this case, the mcca, an unincorporated, nonprofit association of private insurers, adopted a statutorily required "plan of operation,” promulgated by its board of directors. The plan includes a method to calculate premiums for catastrophic claim coverage and generate funds to pay for those claims. Pursuant to the plan, the mcca is authorized to make and collect premium assessments from member 6 insurers. MCL 500.3104(7)(d), (e); MSA 24.13104(7)(d), (e).

The mcca charged its members for two premium payments, the first being sent out in February 1979. League General Insurance Company, a no-fault insurer required to be a member of the mcca and, thus, subject to its premium assessments, did not pay the premium. Instead, League General brought an action in Ingham Circuit Court against the mcca, claiming that the premiums were arbitrary and unreasonable. The mcca, in turn, filed a counterclaim for the unpaid assessments.

Michigan Mutual Insurance Company brought a similar action in which it alleged that the mcca was a state agency subject to the apa, that the mcca had not complied with the rule-making requirements of the apa 7 in adopting its operating plan, and, accordingly, that its plan and its assess- *342 merits were invalid. The Commissioner of Insurance was joined as a party defendant, and the actions were joined for trial. 8

The trial court ruled that the mcca was a state agency, that its operating plan was a “rule” subject to the apa, and that it could not levy premiums against plaintiff until the plan had been properly promulgated pursuant to the apa. The trial court indicated, however, that the mcca could offset indemnification payments to nonpaying member insurers to the extent of their unpaid premium assessments if the mcca promptly promulgated its plan pursuant to apa standards. The mcca appealed. League General cross appealed. The Attorney General intervened.

The Court of Appeals affirmed the lower court’s decision regarding the mcca’s state agency 9 status and that its plan of operation was null and void. 10 The mcca appealed; this Court denied leave on July 11, 1988. On July 27, 1988, the Legislature passed 1988 PA 277, which amended MCL 24.203(2); MSA 3.560(103)(2) and statutorily pronounced the mcca not to be a state agency subject to the apa. 11 Consequently, this Court granted the *343 mcca’s motion for reconsideration and application for leave to appeal in a September 28, 1988, order, limited to two issues: (1) whether the amendment operated retroactively, and (2) if so, whether the statute was constitutional. On July 25, 1989, however, the Court determined it was necessary to ascertain whether the mcca was a state agency before the passage of 1988 PA 277, and issued a supplemental order to that effect. This is the sole issue before us today.

n

ANALYSIS

Under the apa, MCL 24.203(2); MSA 3.560(103)(2), an "agency” is defined as "a state department, bureau, division, section, board, commission, trustee, authority or officer, created by the constitution, statute, or agency action.”

As we determined in Hanselman v Wayne Co Concealed Weapon Licensing Bd, 419 Mich 168; 351 NW2d 544 (1984), the proper interpretation of this statute requires the presence of two characteristics for an "agency.” The entity at issue must be a "state” unit or position and must be created by the constitution, by statute, or by agency action. If these two requirements are met, and it is not specifically exempted, 12 an "agency” is subject to the provisions of the apa. 419 Mich 182.

In Hanselman, this Court had to determine *344 whether the Wayne County Concealed Weapon Licensing Board was an "agency” within the meaning of the apa, so that it would be required to comply with apa provisions. There was no dispute that the licensing board was created by statute 13 and that it was not specifically exempted from the apa. 14 However, we had to ascertain whether the board was a state board in which case it would have been an agency under the apa and subject to those provisions.

The Court of Appeals in the instant case did not embark upon this two-pronged inquiry. It found that because the mcca statute creates a board of directors, 15 and "boards” are specifically included within the apa’s definition of agency, "[t]hat alone leads to the conclusion that the cca’s board of directors, in effect the association itself, must abide by the apa.” 165 Mich App 284. Only then did the Court note the oft-cited test enunciated in In re Advisory Opinion re Constitutionality of 1966 PA 346, 380 Mich 554, 571; 158 NW2d 416 (1968), as applied by the trial court. The Court of Appeals looked to our decision in Hanselman for guidance in applying Advisory Opinion to determine whether the licensing board was a state or local agency. After a very brief analysis, the Court of Appeals determined that application of the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Dairyland Insurance Company v. Cameron Mews
Michigan Court of Appeals, 2023
Theresa M Heller v. Joyce L Dejong Do
Michigan Court of Appeals, 2019
Coalition Protecting Auto No-Fault v. Michigan Catastrophic Claims Ass'n
894 N.W.2d 758 (Michigan Court of Appeals, 2016)
Coalition Protecting Auto No-Fault v. McCa
Michigan Court of Appeals, 2016
Coalition Protecting Auto No-Fault v. McCa
Michigan Supreme Court, 2015
DeLuca v. Amica Mutual Insurance
119 F. Supp. 3d 611 (E.D. Michigan, 2015)
American Home Assurance Co. v. Michigan Catastrophic Claims Ass'n
288 Mich. App. 706 (Michigan Court of Appeals, 2010)
Department of Agriculture v. Appletree Marketing, LLC
761 N.W.2d 277 (Michigan Court of Appeals, 2008)
Farmers Insurance Exchange v. Titan Insurance
651 N.W.2d 428 (Michigan Court of Appeals, 2002)
Karbel v. Comerica Bank
635 N.W.2d 69 (Michigan Court of Appeals, 2001)
Blank v. Department of Corrections
611 N.W.2d 530 (Michigan Supreme Court, 2000)
Tig Insurance v. Department of Treasury
602 N.W.2d 839 (Michigan Court of Appeals, 1999)
Bruggeman v. South Dakota CDCC Board
1997 SD 132 (South Dakota Supreme Court, 1997)
Untitled Texas Attorney General Opinion
Texas Attorney General Reports, 1994
Ullery v. Sobie
492 N.W.2d 739 (Michigan Court of Appeals, 1992)
Opinion No.
Texas Attorney General Reports, 1992
People v. Trinity
471 N.W.2d 626 (Michigan Court of Appeals, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
458 N.W.2d 632, 435 Mich. 338, Counsel Stack Legal Research, https://law.counselstack.com/opinion/league-general-insurance-v-michigan-catastrophic-claims-assn-mich-1990.