Swoope v. Citizens Insurance Company of the Midwest

Summary

The Court held that eligibility for PIP benefits under MCL 500.3113(a) depends on whether the vehicle was unlawfully taken, not whether it was unlawfully operated. Because the Court of Appeals relied on the plaintiff's lack of a driver's license and analyzed unlawful operation rather than unlawful taking, the judgment was reversed and the case was remanded for consideration of whether the vehicle was unlawfully taken. The Court also held that the statutory phrase "taken unlawfully" retained its established meaning after the 2014 amendment.