No-fault benefits; Whether a genuine issue of material fact existed as to whether the injuries arose from the accident at issue; Distinguishing Cruz v State Farm Mut Auto Ins Co; Whether a medical provider “stands in the shoes” of an insured assignor

Holding that plaintiff failed to create a genuine issue of material fact as to whether plaintiff's assignor's (Sams) “​injuries arose from the May 6 accident and therefore, that plaintiff’s treatment of those injuries lacked the required causal connection to establish defendant’s liability,” the court affirmed. The case involved plaintiff’s claims for no-fault benefits stemming from physical-therapy services it provided to Sams after he was allegedly injured in a motor-vehicle accident. “Plaintiff sued defendant to recover the subject benefits as Sams’s assignee. Defendant moved for summary disposition, representing that Sams was involved in a suspiciously similar accident less than a month earlier.” The court concluded that the implication that Sams sustained injuries in the alleged 5/6/19, accident was “negated by the MRI imaging reports produced by defendant. The MRIs taken after the accident reflect no evidence of injury to Sams’s right knee or hip, and only a small central disc protrusion in his lumbar spine. The same disc protrusion was also visualized in an MRI of the same area from [4/17/19]—approximately two weeks before the” May 6 accident. An additional MRI from 4/17/19, “also identified a hernia in Sams’s cervical spine. These records sufficiently rebut the implication that the injuries for which plaintiff provided treatment were caused by the” May 6 accident. The court further noted that plaintiff’s claim that “a provider does not ‘stand in the shoes’ of the injured party following amendment of the [No-Fault Act] does not support its conclusion that summary disposition was erroneously granted.” Finally, plaintiff’s reliance on Cruz was also misplaced.