Spine Specialists of Michigan Pc v. State Farm Auto Insurance Co

CourtMichigan Court of Appeals
DecidedFebruary 11, 2026
Docket367653
StatusUnpublished

This text of Spine Specialists of Michigan Pc v. State Farm Auto Insurance Co (Spine Specialists of Michigan Pc v. State Farm Auto Insurance Co) 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
Spine Specialists of Michigan Pc v. State Farm Auto Insurance Co, (Mich. Ct. App. 2026).

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

SPINE SPECIALISTS OF MICHIGAN, PC, UNPUBLISHED February 11, 2026 Plaintiff-Appellee, 1:59 PM

v No. 367653 Oakland Circuit Court STATE FARM MUTUAL AUTOMOBILE LC No. 2021-186036-NF INSURANCE COMPANY,

Defendant-Appellant.

SPINE SPECIALISTS OF MICHIGAN, PC,

Plaintiff-Appellant,

v No. 371964 Oakland Circuit Court STATE FARM MUTUAL AUTOMOBILE LC No. 2021-186036-NF INSURANCE COMPANY,

Defendant-Appellee.

Before: REDFORD, P.J., and FEENEY and BAZZI, JJ.

PER CURIAM.

These appeals1 involve a dispute over the applicability of the fee schedule delineated under MCL 500.3157 for medical services provided pursuant to the no-fault act, MCL 500.3101 et seq., and the imposition of taxable costs and attorney fees. In Docket No. 367653, defendant, State Farm Mutual Automobile Company, appeals as of right the judgment issued in favor of plaintiff,

1 These appeals were consolidated to advance the efficient administration of the appellate process. Spine Specialists of Michigan PC v State Farm Auto Insurance Co, unpublished order of the Court of Appeals, entered March 19, 2025 (Docket Nos. 367653 and 371964).

-1- Spine Specialists of Michigan, PC, in the amount of $444,053.28. Defendant argues that the trial court abused its discretion by failing to apply the fee schedule iterated under MCL 500.3157 to the costs awarded by the jury for medical services plaintiff administered after July 1, 2021. In Docket No. 371964, plaintiff appeals as of right the trial court’s opinion and order granting in part and denying in part plaintiff’s renewed motion for taxable costs and attorney fees. Plaintiff further contests the trial court’s order partially granting its motion for reconsideration of the issued taxable costs and attorney fees. Plaintiff argues that the trial court erred by failing to award plaintiff the entirety of taxable costs and attorney fees requested. For the reasons set forth in this opinion, we affirm in part, vacate in part, and remand for further proceedings.

I. BASIC FACTS AND PROCEDURAL HISTORY

On January 28, 2021, plaintiff filed a complaint alleging that it had provided medical services to Orlando Benjamin, an individual insured by defendant, for injuries he sustained after his involvement in a motor vehicle accident on September 23, 2019, but defendant failed to properly compensate plaintiff for its administered treatment in accordance with the no-fault act. Defendant filed an answer generally denying the allegations and asserting as affirmative defenses, in part, that “plaintiff’s claims for ‘outstanding charges’ are not recoverable as a matter of law,” and that plaintiff “failed to provide evidence that its ‘outstanding charges’ are reasonable.”

On February 15, 2023, plaintiff moved in limine to “preclude reference to and arguments regarding MCL 500.3157’s ‘fee schedule’, governmental payors, and ‘other insurance,’ ” contending, “It is anticipated that Defendant will attempt to make arguments referencing, elicit testimony concerning, or otherwise seek to introduce evidence of the ‘fee schedule’ contained in amended MCL 500.3157, which took effect on July 1, 2021, and other amendments to the No- Fault Act.” Plaintiff argued that the fee schedule delineated under MCL 500.3157 had “no bearing on the issues to be determined by the jury in this matter,” specifically the reasonableness of plaintiff’s charges for medical services; rather, the presentation of the fee schedule would confuse the jury and be highly prejudicial to plaintiff.

On February 20, 2023, defendant responded that the fee schedule articulated under MCL 500.3157 was pertinent to the underlying matter because “the overwhelming majority” of plaintiff’s charges for medical services were incurred after July 1, 2021, and the statute “establishes the cap for a reasonable charge and reimbursement” for such services provided after July 1, 2021. Defendant further asserted that because the jury was tasked with determining the reasonableness of plaintiff’s charges as a medical provider, defendant was entitled to argue that the statute’s fee schedule was applicable to dates of service after July 1, 2021, such that plaintiff’s charges were unreasonable. On February 22, 2023, the trial court entered an order granting in part and denying in part plaintiff’s motion in limine stating, “Evidence of the fee schedule shall be precluded for all allowable expenses allegedly incurred prior to July 1, 2021. The fee schedule is relevant and not precluded for alleged allowable expenses resulting from dates of service after July 1, 2021.”

On February 22, 2023, plaintiff moved in limine to “preclude defendant from introducing evidence, eliciting testimony, or making arguments contesting the reasonableness of plaintiff’s charges for claims incurred after March 15, 2021,” the date defendant denied Benjamin’s benefits. Plaintiff contended that because defendant did not contest the reasonableness of plaintiff’s fees for

-2- medical services provided after March 15, 2021, defendant should be barred from doing so at trial. Defendant responded that (1) it “owes Plaintiff nothing for the benefits at issue, so logic would be defied at trial were the defense to admit evidence about ‘reasonableness’ of the Plaintiff’s post- March 15, 2021 charges which were denied,” (2) it was plaintiff’s burden to establish the reasonableness of the contested charges, and (3) the court’s February 22, 2023 order indicated that plaintiff “cannot preclude the fee schedule for benefits incurred after 7/1/2021.” The trial court held a hearing regarding plaintiff’s motion in limine on March 1, 2023, and it subsequently issued an order providing:

IT IS HEREBY ORDERED that Plaintiff’s Motion in Limine to Preclude Defendant from Introducing Evidence, Eliciting Testimony, or Making Arguments Contesting the Reasonableness of Plaintiffs Charges for Claims Incurred After March 15, 2021 is granted for the reasons stated on the record.

IT IS FURTHER ORDERED that Defendant is precluded from introducing evidence, eliciting testimony, or making arguments contesting the reasonableness of Plaintiffs charges for claims incurred after March 15, 2021, subject to the Court’s prior ruling on Plaintiffs Motion in Limine to Preclude Reference to and Arguments Regarding MCL 500.3157’s “Fee Schedule”, Governmental Payors, and “Other Insurance”.

Following the release of the jury on the first day of trial, the parties’ counsel disputed the admissibility of evidence pertaining to the fee schedule provided under MCL 500.3157, in light of the trial court’s previous rulings on plaintiff’s motions in limine. When the trial court questioned whether defense counsel had a witness to testify regarding the fee schedule, the following exchange occurred:

The Court: Or do you even know some—do you even have someone who’s going to say, gee, the fee schedule was in effect. This is what they would pay.

[Defense Counsel]: Well, you can go to the website.

[Plaintiff’s Counsel]: Well, I—

[Defense Counsel]: And you can do that. It’s—everyone can do it. Everyone—

The Court: Who’s going to do it?

[Defense Counsel]: Who’s going to do it?

The Court: Yeah.

[Defense Counsel]: Anybody can do it.

The Court: No—

[Defense Counsel]: Jerri Ellis can do it.

-3- [Plaintiff’s Counsel]: I don’t think Ms. Ellis should be allowed to do it here in trial. That was the basis of my motion. Because in her discovery deposition, she said I don’t know where the data comes from. I don’t know how the pricing works under the fee schedule.

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