Uninsured vehicle owner attempting to recover stolen car can't collect PIP benefits

This week, Progressive Michigan Insurance Company prevailed in its dispute with Timothy White over medical expenses incurred when White attempted to recover his stolen car.  White was separated from his wife and did not insure his car:  he claimed it was his intent to park it for the time being.  The car was stolen from White's driveway, however, and White found it hours later, stopped at a gas station.  White approached the vehicle and reached in to remove the keys.  As White reached in the driver's window, however, the thief attempted to drive away, dragging White, and causing him to suffer injuries.

White attempted to recover PIP benefits from Progressive, the insurer of his wife's car.  The Court of Appeals held that regardless of White's reasoning for not insuring his car, and despite the fact that it was on a public road only because it had been stolen from his driveway, White was not eligible to collect PIP benefits.  The Court held that the no fault provision which makes the owner of an uninsured vehicle ineligible for PIP benefits applies without regard to the owner's intent, fault or culpability.