Auto negligence; Serious impairment of body function; MCL 500.3135; McCormick v Carrier; Causation; Motor vehicle accident injury; Wilkinson v Lee; Causation; Cause in fact; Craig ex rel Craig v Oakwood Hosp; Summary disposition; MCR 2.116(C)(10); Patrick v Turkelson

The court held that although plaintiff created a question of fact on whether her condition affected her general ability to lead her normal life, defendants were still entitled to summary disposition because she failed to present evidence causally connecting her claimed impairments to the accident. Plaintiff was rear-ended in 4/23, declined treatment at the scene, and went to the hospital two days later complaining of neck and shoulder pain. Her records showed normal x-rays and a diagnosis of cervicalgia, and later providers noted tendinosis, disc bulges, and a mild spinal curvature. The trial court granted summary disposition after concluding that she had not satisfied the third prong of the serious-impairment test. On appeal, the court held that the trial court erred on that point because plaintiff’s testimony that she missed a month of work, had chronic pain, needed more breaks, struggled with lifting and pushing at her nursing job, and could no longer fully enjoy activities like weightlifting and playing basketball with her son created a factual question under McCormick about whether her general ability to lead her normal life was affected. The court next held, however, that plaintiff still could not recover because she failed to prove causation. It noted that she reported no injury at the scene, the emergency-room records did not identify objective impairments from the crash, and none of the later providers linked the slipped discs, bulging discs, spinal curvature, or tendinosis to the accident. The court also emphasized that a temporal relationship alone is insufficient and that the independent medical examiner stated her complaints were “unrelated to the accident in question.” Affirmed.