William Beaumont Hospital v. Wass

Defendant/third-party plaintiff, Jon Wass, appeals a trial court order granting third-party defendant, Time Insurance Company (Time), summary disposition of Wass’s breach of contract claim. The trial court concluded that because the Office of Financial and Insurance Regulations (OFIR), an administrative agency, had already issued a decision pursuant to the external review procedures in MCL 550.1915(1), the breach of contract claim was barred by res judicata and collateral estoppel. MCL 550.1915(3), however, provides that Subsection (1) does not preclude Wass from seeking other remedies…