June 9, 2026
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seva firm
By Pratheep Sevanthinathan, Esq. The Seva Law Firm
Case: Stanley v. Farmers Insurance Exchange, No. 374881 (Mich. Ct. App. June 9, 2026) (Published)
Court: Michigan Court of Appeals
Panel: Bazzi, P.J., and Rick and Maldonado, JJ.
Decision: Appeal Dismissed — Authored by Rick, J.
Lower Court: Wayne Circuit Court, Case No. 22-015177-NF
Read the full opinion here (https://www.courts.michigan.gov/49c961/siteassets/case-documents/uploads/opinions/final/coa/20260609_c374881_36_374881.opn.pdf)
1.Introduction
In Stanley v. Farmers Insurance Exchange, the Michigan Court of Appeals issued a published opinion dismissing the plaintiff’s appeal for lack of jurisdiction in a first-party no-fault case. The Court held that when a plaintiff agrees to a stipulated dismissal with the same defendant that obtained an unfavorable interlocutory ruling, the plaintiff must expressly reserve the right to appeal that earlier ruling in the stipulated order — or lose the right to challenge it altogether. Because the plaintiff here failed to include any such reservation, the Court found she was not an “aggrieved party” under MCR 7.203(A)(1) and lacked standing to appeal. This is a critical procedural decision that every no-fault practitioner — and every injured claimant — needs to understand.
2.Facts
This case arises from a head-on motor vehicle collision that occurred on December 27, 2021, in Tuscola County, Michigan. Gayla Ruth Stanley was driving eastbound on East Caro Road when an oncoming vehicle lost control, crossed the centerline, and struck her vehicle. Stanley alleged she sustained significant injuries and incurred substantial medical expenses and other losses as a result.
Stanley filed a first-party no-fault action seeking personal protection insurance (PIP) benefits against Auto-Owners Insurance Company and the Michigan Automobile Insurance Placement Facility (MAIPF). She alleged that Auto-Owners was responsible under an applicable no-fault policy, or alternatively, that she was entitled to benefits through the assigned-claims system. Auto-Owners denied liability, and Farmers Insurance Exchange subsequently appeared as the servicing insurer for the assigned-claims plan. The trial court entered a stipulated order dismissing Auto-Owners without prejudice, and the case continued against Farmers alone.
Farmers then moved for partial summary disposition, arguing that Stanley could not recover certain medical expenses because she had assigned her right to those benefits to a medical provider. Stanley disputed that the document at issue constituted a valid assignment. After a hearing, the trial court agreed with Farmers and granted the partial summary disposition, ruling that Stanley could not pursue claims related to those assigned expenses. The court’s order specified it was not a final order.
The parties subsequently entered into a stipulated order on February 28, 2025, dismissing Stanley’s remaining claims against Farmers with prejudice pursuant to an agreement to submit the matter to binding arbitration. That order closed the case and became the final order from which Stanley appealed.
3.Issues
The central question was jurisdictional: Did the Court of Appeals have jurisdiction to hear Stanley’s appeal from a stipulated dismissal order when her actual challenge was directed at an earlier interlocutory ruling — the partial summary disposition on the assignment issue — and the stipulated order contained no reservation of the right to appeal?
More specifically, the Court addressed whether the holding in Jaber v. P & P Hospitality, LLC (2024) — which permitted appeal of an earlier ruling involving one defendant despite a stipulated dismissal with a different defendant — applied when the stipulated dismissal was entered with the same defendant that obtained the earlier ruling.
4.Holding
The Court of Appeals dismissed the appeal for lack of jurisdiction, holding that Stanley was not an aggrieved party under MCR 7.203(A)(1).
The Court’s analysis rested on several well-established principles. First, this Court’s jurisdiction over appeals of right is limited to appeals filed by an aggrieved party from a final judgment or final order under MCR 7.203(A)(1). A party is not aggrieved by an order to which that party has consented, as the Michigan Supreme Court held in Dora v. Lesinski, 351 Mich 579 (1958). A consent judgment or stipulated order reflects the parties’ agreement, not a judicial determination of contested rights, and a party cannot stipulate a matter and then argue on appeal that the resulting action was error.
Second, the Court recognized that a party can preserve the right to challenge an earlier interlocutory ruling by expressly reserving that right in the stipulated dismissal order. However, where a party agrees to a final dismissal with the same opposing party and fails to reserve appellate rights, the stipulated dismissal extinguishes any claim of appeal from earlier rulings involving that party.
Third, the Court distinguished Jaber v. P & P Hospitality, LLC (2024), which held that a plaintiff could seek review of an earlier order involving one defendant despite entering a stipulated dismissal with a different defendant. The Jaber Court’s reasoning turned on the fact that the defendant who benefited from the earlier ruling was not a party to the later stipulated dismissal and therefore could not require the plaintiff to preserve appellate rights in an agreement to which it was not a party. The Jaber Court expressly declined to address the scenario presented in Stanley — where the stipulated dismissal is with the same party that obtained the earlier ruling. The Court held that this case falls “squarely outside” the Jaber framework and that Stanley was required to preserve her appellate challenge in the stipulated dismissal but failed to do so.
5.Conclusion
The Court of Appeals dismissed the appeal for lack of jurisdiction. Because the stipulated order broadly dismissed Stanley’s remaining claims against Farmers with prejudice and contained no reservation of the right to appeal the earlier partial summary disposition ruling, Stanley was not an aggrieved party. The practical result is that the trial court’s ruling — holding that Stanley had assigned her right to certain medical expense benefits to a provider and could not pursue those claims herself — stands, and Stanley lost her opportunity to challenge it on appeal.
6.What Does This Mean for Our Clients?
This is a published opinion, which means it sets binding precedent. It carries an important procedural warning for anyone involved in no-fault litigation — or any civil case, for that matter. Here is what you need to know:
If you agree to a stipulated dismissal, you may be giving up your right to appeal. This is the single most important takeaway. When a case is dismissed by agreement — whether to go to arbitration, to settle some but not all claims, or for any other reason — the Court will treat that agreement as a waiver of any appeal from earlier rulings in the case. If you want to preserve your right to challenge an earlier ruling on appeal, you must include an express reservation in the stipulated order itself.
This rule applies when the stipulated dismissal is with the same party that obtained the earlier ruling. The Court drew a clear line: if the defendant who won the interlocutory ruling is the same defendant involved in the stipulated dismissal, the plaintiff must reserve appellate rights in that dismissal order or lose them. This is distinct from the Jaber scenario, where the earlier ruling involved a different defendant entirely.
Assignment of benefits remains a live issue in no-fault cases. While the Court did not reach the merits of the assignment question, the underlying dispute — whether a document constituted a valid assignment of PIP benefits from a claimant to a medical provider — is a common issue in Michigan no-fault litigation. Assignments can limit a claimant’s ability to pursue benefits directly. If you signed any paperwork from a medical provider after your accident, it is important to understand whether you may have assigned some of your rights.
Procedural missteps can be just as costly as losing on the merits. Stanley may have had a strong argument on the assignment issue, but she never got the chance to make it because of a procedural error. This underscores why having experienced no-fault counsel is so important — not just for the substantive legal arguments, but for navigating the procedural requirements that can make or break a case.
If you have been injured in a motor vehicle accident and are dealing with an insurance company that is denying or limiting your benefits, contact The Seva Law Firm. We understand the procedural and substantive complexities of Michigan no-fault law, and we fight to make sure our clients’ rights are protected at every stage of the process.
Pratheep Sevanthinathan is the owner and managing attorney of The Seva Law Firm, located at 100 W. Big Beaver Rd, Suite 500, Troy, MI 48084. He can be reached at (248) 385-5704.
This article is for informational purposes only and does not constitute legal advice. Every case is different, and past results do not guarantee future outcomes.