The Michigan Supreme Court's decision in Abdulla v Progressive Southeastern Insurance Company provides important guidance on who qualifies as an “owner” of a motor vehicle under Michigan's No-Fault Act.

The plaintiff was injured while operating a commercial tractor titled to an LLC that he solely owned. Although the LLC held legal title, the plaintiff was the tractor's exclusive driver, controlled its operation and maintenance, chose whether to accept hauling assignments, and had regularly used the vehicle for more than six months.

The Court held that the plaintiff was a statutory “owner” under MCL 500.3101 because he had the right to use the tractor in a manner consistent with ownership for more than 30 days. The fact that the vehicle was titled to a separate LLC did not prevent the plaintiff from also qualifying as an owner under the No-Fault Act.

Because the required no-fault security was not in effect for the tractor at the time of the accident, the plaintiff was barred from recovering PIP benefits under MCL 500.3113(b).

Key takeaway: Michigan's No-Fault Act focuses on the practical right to use and control a vehicle—not title alone. A person who regularly and exclusively operates a vehicle may be deemed an owner even when a separate business entity holds legal title. If the required coverage is not maintained, that person may be disqualified from receiving PIP benefits.