Action seeking personal protection insurance (PIP) benefits for a trip & fall in a parking lot; MCL 500.3105(1); Putkamer v. Transamerica Ins. Corp. of Am.; Whether plaintiff was injured while entering into her vehicle; MCL 500.3106(1)(c); King v. Aetna Cas. & Sur. Co.; Hunt v. Citizens Ins. Co.; McCaslin v. Hartford Accident & Indem.

The court held that because plaintiff had not yet begun entering into her vehicle when she fell, defendant-no-fault insurer was entitled to summary disposition. Plaintiff sought PIP benefits for injuries she sustained when she tripped and fell in a store parking lot. Defendant denied payment on the basis that plaintiff was not entering her vehicle at the time of the injury. The trial court denied defendant’s motion for summary disposition, finding a factual issue remained as to whether plaintiff was in the process of entering her vehicle at the time of her fall. Plaintiff “had not entered, or begun to enter, her vehicle. Indeed, she was merely preparing to enter her vehicle when she fell. After plaintiff placed her purchases on the front passenger seat of her car, plaintiff closed the driver’s side door and walked away. She did not start her car, or leave the door open. Plaintiff had not yet reached her car when she fell, and never touched her car after leaving to return the shopping cart. Clearly, plaintiff intended to enter into her vehicle, but intent to enter a vehicle is insufficient to warrant coverage under MCL 500.3106(1)(c).” Reversed and remanded for entry of summary disposition in defendant’s favor.