In Foremost Ins. Co. v. Allstate Ins. Co. (1992) 439 Mich. 378, 383 486 N.W.2d 600, 602, Michigan Supreme Court, Justice Brickley explained that one point of view regarding the automobile policy's conversion exception is that the exception "is intended to prevent a lienholder from recovering where the owner of the vehicle fails to make payment and removes the vehicle from the reach of the lienholder. In such a case, the inability of the lienholder to enforce its security interest results from a credit problem rather than a risk of loss of or damage to the property for which the lienholder obtained insurance. Therefore, in a case where the purchaser of an automobile under a conditional sales contract tendered a bad check to the seller and thereafter absconded with the car, the California Supreme Court held that the conversion exclusion in the insurance policy prevented recovery by the lienholder.