A single stipulated dismissal cost a no-fault claimant her appeal against Farmers - and handed Michigan carriers a sharp lesson in protecting courtroom wins.
On June 9, 2026, the Michigan Court of Appeals tossed the claimant's appeal against Farmers Insurance Exchange, ruling it had no authority to hear it.
The case began with a wreck. On December 27, 2021, the claimant was heading east on East Caro Road in Tuscola County when an oncoming vehicle lost control, crossed the centerline, and hit her car head-on. She alleged significant injuries and filed a first-party no-fault claim for personal protection insurance (PIP) benefits.
She initially sued Auto-Owners Insurance Company and the Michigan Automobile Insurance Placement Facility. Farmers later stepped in as the servicing insurer for the assigned-claims plan and took over the defense. Auto-Owners was dismissed without prejudice, and the case moved forward against Farmers alone.
The turning point came on September 13, 2024. Farmers won partial summary disposition - an early ruling that throws out part of a case - by arguing the claimant had assigned her right to certain medical benefits to a provider. She disputed that the document was a valid assignment. The trial court agreed with Farmers, and its order specifically noted that it was not a final order.
Months later, on February 28, 2025, both sides signed a stipulated order dismissing the remaining claims with prejudice and agreed to send the matter to binding arbitration. That closed the case. The claimant then appealed the assignment ruling.
The court never weighed in on whether that ruling was correct. It dismissed the appeal outright. Under Michigan court rule MCR 7.203(A)(1), only an aggrieved party can appeal as of right, and the court held that someone who agrees to an order is not aggrieved by it. Because the claimant consented to the final dismissal without reserving her right to appeal, the court found she gave up that right.
The panel drew a sharp line from an earlier decision, Jaber v P & P Hospitality, where a plaintiff was allowed to challenge an earlier ruling after a stipulated dismissal - but only because the defendant who won that ruling was not part of the later deal. Jaber left open what happens when the plaintiff settles with the same party that won. This case answered it. Farmers both won the ruling and signed the dismissal, so the claimant had to reserve her appeal rights in that agreement, and she did not.
For carriers and claims teams, the takeaway is plain. When a no-fault case ends in a stipulated dismissal with prejudice, the wording of that order can cement earlier wins. If the plaintiff fails to reserve appellate rights, a favorable interlocutory ruling can become effectively unappealable - as long as the carrier that won it is a party to the dismissal. The opinion is published, making it binding precedent in Michigan.
