Auto Club prevails in argument that "one year back" rule should apply to PIP benefits sought by entity who paid in error

SMART, the transportation authority, paid PIP benefits for a rider who was injured when a bus accelerated rapidly.  It then learned, more than a year later, that the injured man resided with a family member who had AAA No Fault insurance.  Under the Michigan rules, AAA should have been the first priority insurer with regard to the injured man's related medical bills, so SMART sued AAA to recover the expenses it paid.  The Court held that the "one year back" rule applied and that since SMART didn't file suit within one year of incurring the expenses, it could not sue to recover the mistaken payment.