Bianchi v. Automobile Club of Michigan

In Bianchi v. Automobile Club of Michigan, 437 Mich. 65, 70; 467 N.W.2d 17 (1991), the plaintiff was injured when he collided with an uninsured automobile while riding his wife's motorcycle. The insurance policy covering the wife's motorcycle did not provide uninsured motorist coverage. The insurance policy covering the plaintiff's wife's automobile, however, did provide such coverage, and the plaintiff applied for benefits under that policy. The "defendant denied the claim on the basis of the policy's 'other owned vehicle' exclusion, which stated that injuries suffered while occupying a motor vehicle owned by the plaintiff's wife, other than the vehicle specifically named in the policy, were not covered by the policy." Bianchi, supra at 67. The Supreme Court initially noted that because uninsured motorist coverage was not mandatory in Michigan, the terms of the no-fault act, MCL 500.3101 et seq.; MSA 24.13101 et seq., were not at issue in the case. Bianchi, 437 Mich. at 68. The Court went on to hold that in the specific instance of the Bianchi case, a motorcycle was a motor vehicle and thus the "other owned vehicle" exclusion in the plaintiff's wife's automobile policy applied. Bianchi, 437 Mich. at 73. However, the Court explained that its decision was a matter of contractual interpretation that was "based on the language of the policy" involved in the case. Bianchi, 437 Mich. at 73. Most importantly, while in Bianchi the policy's definition of the relevant term, "motor vehicle," excluded types of vehicles that might otherwise fit the broad definition of the term, motorcycles were not among the stated exceptions. Bianchi, 437 Mich. at 71.