MacDonald v. State Farm Mutual Ins Co

In MacDonald v. State Farm Mutual Ins Co, 419 Mich. 146; 350 N.W.2d 233 (1984), the Supreme Court of Michigan explained this provision. The Court held that the benefits provided for under section 3107(1)(b) are payable to "compensate the injured person for income he would have received but for the accident." Id., 152. In MacDonald, the plaintiff sustained disabling injuries in an automobile accident on November 10, 1976. Two weeks later, on November 25, 1976, the plaintiff suffered a heart attack. Either occurrence by itself would have prevented plaintiff from working. Id., 150. Our Supreme Court held that the plaintiff was eligible for no-fault work loss benefits for the two-week period following the automobile accident--because that period of work loss was attributable to the accident--but became ineligible for no-fault benefits following the heart attack--because plaintiff would have been unable to work for that period even if he had not had the automobile accident. The Court explained: Work-loss benefits are available to compensate only for that amount that the injured person would have received had his automobile accident not occurred. Stated otherwise, work-loss benefits compensate the injured person for income he would have received but for the accident. In the present case, plaintiff would have worked and earned wages for two weeks, until the date of his heart attack. After that date plaintiff would have earned no wage even had the accident not occurred and, therefore, is ineligible for work-loss benefits after that date under 3107(b). Id., 152.