(September 2, 2022, 9:41 AM EDT) -- GRAND RAPIDS, Mich. — A Michigan appeals panel held Aug. 18 that a lower court erred in granting an insurer’s motion for summary disposition on reconsideration in a lawsuit seeking recovery of personal injury protection (PIP) benefits under the state’s no-fault act, finding that reversal is warranted in light of Haydaw v. Farm Bureau Ins. Co., which held that “statements made during the course of litigation do not implicate an insurance policy's fraud or misrepresentation clause and that such a clause may not be relied on by the insurer to justify a denial of benefits.”...