Action for personal protection insurance (PIP) benefits under the No-Fault Act; MCL 500.3105(1); Whether the use of the plaintiff’s vehicle was closely related to its transportational function at the time of injury; McKenzie v. Auto Club Ins. Ass’n; Block v. Citizens Ins. Co. of Am.; Drake v. Citizens Ins. Co.; Whether dragging items behind a vehicle precludes coverage; Smith v. Community Serv. Ins. Co.; Construction of the No-Fault Act; Churchman v. Rickerson; Putkamer v. Transamerica Ins. Corp. of Am.; McMullen v. Motors Ins. Corp.; “As a motor vehicle” defined; Incidental involvement of a motor vehicle; Morosini v. Citizens Ins. Co. of Am.; Thornton v. Allstate Ins. Co.; Marzonie v. ACIA; Bourne v. Farmers Ins. Exch.; Gooden v. Transamerica Ins. Corp.; Winter v. Automobile Club of MI; Principle that there must be “a causal connection, which is more than fortuitous, incidental or but for, between the use of the motor vehicle and the injury sustained”; DAIIE v. Higginbotham

The court held that the trial court did not err when it held that the plaintiff was entitled to PIP benefits. He and his wife were using plaintiff’s truck to move a safe from their garage. As his wife began to drive, with plaintiff standing outside the truck, the safe fell over and landed on his leg. His leg was eventually amputated below the knee. He sought PIP benefits from the defendant-insurer, Farm Bureau, claiming the injury occurred when his wife accelerated the truck over the pavement, causing the safe to fall out of the bed of the truck. Defendant denied the claim, arguing “plaintiff’s injuries did not arise out of the transportational function of a motor vehicle because the truck was either being used as an immobile anchor point for the rope or was pulling the skidding safe.” The trial court found that plaintiff was entitled to PIP benefits under either version of events. On appeal, the court rejected defendant’s argument that the trial court erred in concluding that plaintiff was using his truck as a motor vehicle at the time the injury occurred. It noted that “the truck was moving for the purpose of transporting or conveying the safe from one location to another when the injury occurred. Thus, ‘the requisite nexus between the injury and transportation function of the motor vehicle’ is present.” Further, it distinguished the cases cited by defendant, noting that in each case the use of the vehicle was incidental, which was not the case here. “[P]laintiff was using a truck to move or transport a very heavy safe, at a minimum, from his garage to his driveway. It is normal and foreseeable to use a truck, attached with a trailer hitch, to move heavy objects.” Thus, “plaintiff’s injury was closely related to the transportational function of the vehicle and, therefore, arose out of the operation, ownership, maintenance, or use of a motor vehicle ‘as a motor vehicle.’” Affirmed.