Beyond Unlicensed Driving: Pena-Cruz Refines Michigan’s Unlawful-Taking Analysis

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Pena-Cruz v. State Farm Mutual Automobile Insurance Co. __Mich App__,__NW3d__ (2026) is a recent published case from the Michigan Court of Appeals that refines the unlawful taking defense to payment of Michigan no fault benefits. Pena-Cruz addresses whether MCL 500.3113(a) barred Tiburcio Pena-Cruz from recovering no-fault benefits on the theory that the F-150 he was driving was “taken unlawfully.” The Court of Appeals reconsidered the case after the Michigan Supreme Court’s remand in light of…
By: Miller Johnson
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Beyond Unlicensed Driving: Pena-Cruz Refines Michigan’s Unlawful-Taking Analysis