Michigan court expands no-fault insurer subrogation rights, overturns 33-year precedent

The decision, published on April 20, 2026, came from a seven-judge special panel of the Michigan Court of Appeals (Docket No. 366229). The panel unanimously overruled the 1993 decision in Citizens Ins Co v Pezzani, which had held that no-fault insurers were barred from pursuing subrogation claims against tortfeasors who were not motorists. For insurers writing no-fault auto coverage in Michigan, the implications are immediate and practical.