How Much Medical Coverage Can a Motorcycle Accident Victim Get in Michigan?

Since the Michigan No-Fault Law underwent drastic changes in 2019, there has been significant uncertainty about many issues. One of the most controversial issues was the way motorcyclists seemed to be left unprotected now that motor vehicle owners could cap medical coverage.

Under the old law, everyone had unlimited personal injury protection (PIP) policies. This meant an injured motorcyclist could still get all their medical bills paid by the other driver's auto insurance following a crash. However, after the 2019 amendments, policyholders could purchase limited PIP policies, and under the law, motorcycle drivers were required to have the PIP coverage selected by the driver.

This created strange situations. A motorcyclist may have purchased unlimited medical PIP coverage for their own auto insurance. Still, because the law demanded motorcyclists accept the PIP coverage selected by the driver or owner of the car involved in the crash, motorcyclists were stuck with this lower amount.

The Michigan Court of Appeals answered this question in the recently decided Mary Free Bed v. Esurance, docket no. 370846, (published 3/2/2026).

In the case, Aaron Slade was catastrophically injured, including a severe traumatic brain injury, when he rode his cousin's motorcycle the wrong way down a street in Muskegon and collided head-on with a car driven by Haley Tanner.

At the time, Ms. Tanner was insured through Esurance with $250,000 in PIP coverage. Mr. Slade's parents had unlimited PIP through USAA, and Mr. Slade qualified for this coverage because he was a relative domiciled in their household. Mary Free Bed provided medical care to Mr. Slade, totaling $1,183,565.59 in charges. Esurance paid only $113,307.30 before claiming the entire $250,000 PIP policy was exhausted. Mr. Slade and his family turned to USAA and their unlimited medical policy. Still, USAA refused to pay, arguing that Esurance was a higher-priority payer and had already provided coverage.

Michigan's No-Fault PIP Law: Before and After 2019

The Pre-2019 System

Michigan's no-fault act, in place since 1973, required all motor vehicle owners to carry Personal Injury Protection (PIP) insurance. The core promise of the system was unlimited lifetime medical benefits for anyone injured in a motor vehicle accident.

For motorcyclists specifically, the law recognized they were not required to carry PIP insurance themselves, but allowed them to claim PIP benefits from motor vehicle insurers. The insurer responsible for paying the claim was based on an order of priority. The order of priority was the following (MCL 500.3114(5)):

1. The insurer of the owner of the motor vehicle involved in the accident.

2. The insurer of the driver of the motor vehicle involved in the accident.

3. The motor vehicle insurer of the driver of the motorcycle involved in the accident.

4. The motor vehicle insurer of the motor vehicle owner involved in the accident.

5. The Michigan Assigned Claims Plan (MACP).

This meant that if a motorcyclist was hit by a vehicle, the motor vehicle's insurance carrier paid all the medical bills, even if the motorcyclist was at fault for the crash. Because all policies provided unlimited benefits, the injured motorcyclist did not really care who paid. That insurer simply paid all outstanding medical bills.

The 2019 Amendments: A Major Shift

Facing criticism over skyrocketing auto insurance costs, the Michigan Legislature enacted a new law that dramatically restructured PIP coverage. The key changes included new PIP coverage caps, with levels ranging from unlimited medical coverage down to $50,000. In some situations, the driver could even opt out entirely if they had qualifying health insurance.

What did not change was the order of priority. The injured motorcyclist still had to turn to the insurance carrier of the motor vehicle involved in the crash for the payment of medical bills. But now the motorcyclist was stuck with whatever coverage the owner or driver chose. If the car had only $50,000 in PIP, the motorcyclist would have to accept this limited amount, even if he had purchased unlimited medical coverage for his own vehicles.

The practical consequence was enormous. What used to be a simple "find the highest-priority insurer" exercise became far more complicated, because that insurer might now have a $250,000 cap, or no coverage at all, leaving catastrophically injured people like Mr. Slade with no insurance to pay outstanding medical bills.

Can a Motorcyclist Move Down the Order of Priority to Get More Coverage?

The main question the court addressed in the Mary Free Bed case was whether Mr. Slade could move down the order of priority and claim benefits through his family's unlimited auto policy once the $250,000 Esurance policy for the motor vehicle was exhausted.

USAA Insurance argued no, Mr. Slade could not move down. The carrier argued that Esurance is a higher priority, that Esurance paid to its limit, and that was it. The law only provides one responsible insurance carrier following a crash.

The Kent County Circuit Court trial judge agreed with Esurance. However, the Michigan Court of Appeals disagreed and reversed the decision for several reasons.

Motorcyclists Can Move Down to Their Own Auto Insurance Policy

MCL 500.3114(5) says injured motorcyclists "shall claim benefits from insurers in the following order of priority." The statute tells you the order to proceed, but contains no language stopping you once the first insurer's limits are exhausted. The word "shall" governs the sequence, not the ceiling.

Before 2019, the inquiry stopped at the first-in-priority insurer, not because the statute said so, but because unlimited policies made further inquiry unnecessary. With limited coverage now available, the question of what happens after exhaustion is new, and the statute's plain language does not foreclose going further down the list.

In addition, the old law (former MCL 500.3115(3)) explicitly prevented stacking of multiple policies. The Legislature removed it in 2019. The court reasoned that if lawmakers wanted to keep that bar, they would have kept it.

Further, MCL 500.3107c(6) supports multi-policy recovery. This provision states that when benefits are payable under two or more policies, recovery is capped at the highest available coverage limit under any one policy. This provision does not distinguish between policies at the same or different priority levels. Instead, it considers multiple policies and limits the aggregate recovery to the highest single-policy limit. Since USAA's policy is unlimited, and the aggregate cap equals the highest available limit (unlimited), there is no ceiling on what Mr. Slade can recover.

Last, the Court reasoned the spirit of the No-Fault Act was to provide prompt payment of medical bills following a crash. Limiting a catastrophically injured motorcyclist to a $250,000 policy, when his own family paid for unlimited coverage, conflicts with the act's core purpose of providing "assured, adequate, and prompt" reparation.

What This Means for Injured Motorcyclists Going Forward

This decision is enormously significant, and its practical effects will be felt in several ways.

For Injured Motorcyclists

The ruling means that a catastrophically injured rider is no longer trapped by whatever coverage limit the other driver happened to choose. If the at-fault driver's insurer has a $250,000 cap, the motorcyclist (or their medical provider) can continue down the order of priority to access their own family's additional coverage.

For Families Who Purchased Unlimited Coverage

This decision gives real meaning to the choice to pay higher premiums for unlimited PIP coverage. Before this ruling, a family could pay for unlimited protection, only to have it rendered irrelevant if a lower-coverage driver hit their motorcyclist relative first in the priority order. That injustice is now corrected.

For Medical Providers

Hospitals and rehabilitation centers like Mary Free Bed, which are expressly permitted to bring direct claims under MCL 500.3112, can now pursue multiple auto insurers when the highest-priority policy is capped. This is particularly important in catastrophic injury cases where charges routinely exceed $250,000.

For Auto Insurers

Companies like USAA that issue unlimited PIP policies must now account for the reality they may be required to pay even when a higher-priority insurer exists but has limited coverage. This may eventually influence how unlimited policies are priced or underwritten.

The Aggregate Cap Still Applies

It is important to note that the total recovery across all policies is still capped at the highest available coverage limit under any one policy (MCL 500.3107c(6)). Here, since USAA's policy is unlimited, that cap is effectively unlimited. But if both policies had $250,000 limits, the injured person could not recover $500,000 total. The ceiling would remain $250,000.

Michigan Motorcycle PIP Coverage: Key Scenarios at a Glance

Bottom Line: What the Mary Free Bed Ruling Means for Michigan Motorcyclists

This case resolves a critical question created by the 2019 no-fault reforms. When the Legislature allowed drivers to choose limited PIP coverage, it inadvertently created a scenario where injured motorcyclists could be left with grossly inadequate compensation simply because the other driver chose a cheap policy. The Court of Appeals has now held that Michigan's priority system is a ladder to be climbed, not a door that slams shut at the first rung.

Frequently Asked Questions: Michigan Motorcycle Accident Medical Coverage

How much medical coverage can a motorcycle accident victim get in Michigan?

Following the 2026 Mary Free Bed v. Esurance ruling, a Michigan motorcycle accident victim can potentially access coverage beyond the first insurer's PIP limit. The victim can move down the order of priority to additional auto insurance policies, up to the highest available coverage limit under any one policy in that chain.

What is the order of priority for Michigan motorcycle accident PIP claims?

Under MCL 500.3114(5), the order of priority is: (1) insurer of the motor vehicle owner, (2) insurer of the motor vehicle driver, (3) insurer of the motorcycle driver, (4) insurer of the motorcycle owner, and (5) the Michigan Assigned Claims Plan (MACP).

Can a Michigan motorcyclist use their own insurance if the other driver's coverage runs out?

Yes. The Michigan Court of Appeals ruled in 2026 that once the highest-priority insurer's policy limits are exhausted, the injured motorcyclist can move down the order of priority and access coverage from the next insurer in line, including their own family's auto insurance policy.

Does Michigan's no-fault law cover motorcycle accidents?

Motorcyclists are not required to carry PIP insurance themselves, but they can claim PIP benefits from the motor vehicle insurer involved in the crash. The 2019 amendments allowed those insurers to carry limited coverage, which created gaps that the Mary Free Bed ruling now helps address.

What is the aggregate cap on Michigan motorcycle PIP recovery?

Under MCL 500.3107c(6), the total recovery across all policies is capped at the highest available coverage limit under any single policy in the priority chain. If the highest policy is unlimited, the recovery is effectively unlimited. If all policies are capped, the ceiling equals the highest single-policy limit.

Contact Our Michigan Motorcycle Accident Experts Today

If you or a loved one was injured in a motorcycle accident, do not assume you are limited to what the other driver's insurance will pay. Michigan law may entitle you to far more coverage than you think.

Call the Lee Steinberg Law Firm today at 1-800-LEE-FREE (1-800-533-3733)

for a 100% free consultation. We have won millions for victims across Michigan, and we never charge a fee until we win your case.