Robert Banker Sr v. Citizens United Reciprocal Exchange

Michigan Court of Appeals·Decided August 10, 2026·No. 374356·Unpublished

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

ROBERT BANKER, SR., UNPUBLISHED August 10, 2026

Plaintiff/Counterdefendant-Appellee, 11:08 AM

v No. 374356 Wayne Circuit Court

CITIZENS UNITED RECIPROCAL EXCHANGE LC No. 23-004606-NF d/b/a CURE AUTO INSURANCE,

Defendant/Counterplaintiff/Third- Party Plaintiff-Appellant,

and

ALLSTATE PROPERTY AND CASUALTY INSURANCE COMPANY,

Defendant-Appellee,

and

ASCENSION PROVIDENCE HOSPITAL, MEDICAL DEVICE SPECIALTY INC., and MICHIGAN SURGERY SPECIALISTS,

Third-Party Defendants,

and

SURGEONS CHOICE MEDICAL CENTER,

Third-Party Defendant-Appellee.

Before: LETICA, P.J., and O’BRIEN and REDFORD, JJ.

PER CURIAM.

Defendant/counterplaintiff/third-party plaintiff, Citizens United Reciprocal Exchange, doing business as CURE Auto Insurance, appeals as of right a consent judgment in which CURE reserved the right to challenge the trial court’s earlier orders denying CURE’s motion for summary disposition and granting the motion for summary disposition filed by defendant, Allstate Property and Casualty Insurance Company (Allstate). CURE argues that the trial court erred by denying CURE’s motion for summary disposition because, plaintiff/counterdefendant, Robert Banker Sr. aided nonparty Robert Banker. Jr. in fraudulently procuring a policy from CURE, so Banker Sr. should not be considered an innocent third party. Agreeing with the trial court that there is no evidence that Banker Sr. committed any fraud in procuring the policy, we affirm.

I. BACKGROUND

At all relevant times, Banker Jr. lived with his mother, Theresa Banker and Banker Sr.

Banker Jr. owned a 1999 Jeep Cherokee and a 2000 Jeep Cherokee. Banker Sr. primarily drove the 2000 Jeep. Banker Jr. applied for an auto insurance policy with CURE for both of his vehicles on December 16, 2022. According to Banker Jr., Banker, Sr. “told [him] to make sure [he] got insurance” on the 2000 Jeep, but Banker Sr. was not present when Banker Jr. applied for the insurance and did not provide Banker Jr. with any information, though Banker Sr. was aware that Banker Jr. had applied for the policy.

In the application, CURE required Banker Jr. to list “[a]ll household members . . . as potential drivers or residents,” but Banker Jr. listed only “Robert Banker”1; he did not include Banker Sr. or Theresa. Upon receiving Banker Jr.’s application, CURE issued him a policy that listed “Robert Banker” as named insured. On the same day that Banker Jr. submitted his application, CURE sent a letter to him requesting that he notify CURE if the list of household members in his application was not accurate. Banker Jr. never responded to this request.

On December 30, 2022, Banker Jr. asked Banker Sr. to call CURE to take the 2019 Jeep off the CURE policy and add a recently purchased 2016 Jeep Cherokee to the policy. During the phone call,2 Banker Sr. told the CURE representative that he was “trying to transfer one vehicle off my policy and put[] another one on.” He provided the policy number, then stated the policyholder’s name was “Robert Eugene Banker.” After Banker Sr. gave an e-mail address different than the one CURE had on file, Banker Sr. said to “leave [the e-mail address] like it is,” adding, “I’m just doing it for him cause he’s at work.” Banker Sr. asked to remove the 1999 Jeep from the policy, then provided vehicle information for the 2016 Jeep. When the CURE representative asked how the 2016 Jeep would be used, Banker Sr. said that “he’s just gonna be using it to drive to work.” When the CURE representative asked if the 2016 Jeep would be titled

1 Banker Jr. listed his birthdate as the birthdate of the “Robert Banker” identified in the application.

2 CURE filed a recording of this phone call with this Court. Banker Sr. and Allstate argue this Court should not consider the recording because CURE did not file it in the trial court. Although the electronic file of the recording is not part of the lower court record, CURE indicated that it included the recording with its motion for summary disposition in the trial court, and the recording is indeed identified as an exhibit in that filing. We therefore consider the recording part of the lower court record and address its content on appeal.

under “your name,” Banker Sr. said yes and identified the owner as “Robert Banker.” When the CURE representative asked about how the vehicle was being financed, Banker Sr. had the CURE representative wait while he called Banker Jr. to ask for that information, then provided it to the CURE representative.

On January 6, 2023, Banker Sr. was driving the 2000 Jeep when another vehicle failed to yield and hit the 2000 Jeep head on. CURE received a claim for PIP benefits from “Robert Banker” on January 8, 2023. CURE ran a search and identified Banker Sr. and Theresa as possible household members that were not listed on the policy, which prompted CURE to send another letter to Banker Jr. inquiring about his household members. Banker Jr. again did not respond, and CURE later identified Banker Sr. as the PIP claimant and a member of Banker Jr.’s household.

CURE refused to pay Banker Sr.’s benefits, prompting Banker Sr. to file this action. CURE then sent Banker Jr. a letter declaring his policy “void from the date of inception” because Banker Jr. fraudulently obtained the policy by misrepresenting his household members in the application. Banker Sr. then applied for benefits through the Michigan Assigned Claims Plan, which assigned Banker Sr.’s claim to Allstate, who was added as a party to this action. CURE was also allowed to file a third-party complaint against Ascension Providence Hospital, Michigan Surgery Specialists, Medical Device Specialty Inc, and Surgeons Choice Medical Center (collectively the third-party-defendant providers), who all treated Banker Sr. following the collision.

CURE and Allstate eventually filed competing motions for summary disposition under MCR 2.116(C)(10). Allstate argued that CURE was the higher-priority insurer responsible for paying Banker Sr.’s benefits because CURE had a policy with Banker Jr., and Banker Sr. was Banker Jr.’s resident relative. Allstate recognized that CURE had rescinded its policy with Banker Jr. on grounds that Banker Jr. engaged in fraud when procuring the policy, but Allstate contended that this rescission should not extend to Banker Sr. because he was an innocent third party and the equities weighed against rescission. In its competing motion, CURE argued that it was entitled to rescind its policy with Banker Jr. as a matter of law, and that this rescission should be extended to Banker Sr. because the equities weighed in favored doing so. As part of the latter argument, CURE contended that Banker Sr. was not only aware of Banker Jr.’s fraud but “took an active role” in it by instructing Banker Jr. to purchase insurance for the 2000 Jeep and by calling CURE to add the 2016 Jeep to Banker Jr.’s policy without adding himself to the policy as a household member. CURE asserted that Banker Sr.’s involvement in—or at the very least knowledge of—Banker Jr.’s fraud weighed heavily in favor of extending the rescission of Banker Jr.’s policy to Banker Sr.

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

Robert Banker Sr v. Citizens United Reciprocal Exchange, (Mich. Ct. App. 2026).

Robert Banker Sr v. Citizens United Reciprocal Exchange (Robert Banker Sr v. Citizens United Reciprocal Exchange) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Federated Insurance v. Oakland County Road Commission
715 N.W.2d 846 (Michigan Supreme Court, 2006)
Sauer v. Rhoades
62 N.W.2d 634 (Michigan Supreme Court, 1954)
Derderian v. Genesys Health Care Systems
689 N.W.2d 145 (Michigan Court of Appeals, 2004)
Ali Bazzi v. Sentinel Insurance Company
919 N.W.2d 20 (Michigan Supreme Court, 2018)
Farm Bureau Gen. Ins. Co. of Mich. v. ACE Am. Ins. Co.
919 N.W.2d 394 (Michigan Supreme Court, 2018)