If this opinion indicates that it is “FOR PUBLICATION,” it is subject to 

revision until final publication in the Michigan Appeals Reports.

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S T A T E O F M I C H I G A N

C O U R T O F A P P E A L S

RANDALL SHAW and HILLARY SHAW,

Plaintiff-Appellees,

UNPUBLISHED

March 30, 2023

v No. 360846

Oakland Circuit Court

KAMIL MARCIN NOWAKOWSKI, LC No. 2020-180321-NI

Defendant/Cross-Defendant,

and

THE AUTO CLUB GROUP, doing business as AAA 

AUTO CLUB GROUP,

Defendant-Appellant,

and

CRISPELLI’S LLC,

Defendant/Cross-Plaintiff.

Before: CAVANAGH, P.J., and MARKEY and BORRELLO, JJ.

PER CURIAM.

Defendant, The Auto Club Group (defendant), appeals by leave granted an order denying 

its motion for summary disposition in this case concerning underinsured motorist (UIM) benefits. 

Shaw v Nowakowski, unpublished order of the Court of Appeals, entered May 27, 2022 (Docket 

No. 360846). We affirm.

I. BACKGROUND

Plaintiffs were driving westbound when defendant/cross-defendant, Kamil Nowakowski,

crossed the center line and struck plaintiffs’ vehicle head-on. Nowakowski, who before the crash 
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consumed alcohol at defendant/cross-plaintiff’s, Crispelli’s LLC’s, restaurant, was intoxicated at 

the time of the crash. At all relevant times, plaintiffs’ vehicle was insured by defendant. In their 

first amended complaint, plaintiffs sued Nowakowski and claimed he was liable under the 

Michigan Motor Vehicle Code, MCL 257.1, et seq., and owner liability under MCL 257.401.

In their second amended complaint, plaintiffs added defendant and claimed defendant 

wrongfully denied them underinsured motorist (UIM) benefits. Plaintiffs noted that their UIM 

policy contained two limits of liability: (1) a $250,000 per-person limit, and (2) a $500,000 peraccident limit. Nowakowski had a $300,000 combined single-limit policy of insurance. Plaintiffs 

alleged that defendant improperly determined that Nowakowski’s vehicle was not “underinsured” 

since his policy limit was greater than the $250,000 per-person limit of plaintiffs’ policy and denied 

their claims for UIM benefits. Plaintiffs requested the trial court to declare they were entitled to 

UIM benefits and determine the proper calculation of UIM benefits.

Plaintiffs filed their third amended complaint, adding Crispelli’s as a party. Plaintiffs 

claimed Crispelli’s was liable for furnishing alcohol to Nowakowski while visibly intoxicated. 

Crispelli’s answered and filed a cross-claim against Nowakowski asserting that Crispelli’s was 

entitled to full indemnification from Nowakowski if a jury determined Nowakowski was served 

alcohol while visibly intoxicated.1

Defendant moved for summary disposition under MCR 2.116(C)(10), arguing that 

plaintiffs were not entitled to UIM benefits because, under the terms of plaintiffs’ insurance policy,

Nowakowski’s motor vehicle was not an underinsured vehicle; his $300,000 policy limit was 

greater than plaintiffs’ $250,000 per-person policy limit. Defendant claimed that the $250,000 

per-person limit in plaintiffs’ policy applied rather than the $500,000 per-accident limit. Further, 

citing Wilkie v Auto-Owners Ins Co, 469 Mich 41; 664 NW2d 776 (2003), defendant argued that 

the UIM benefit limit should be reduced by the limit of Nowakowski’s policy, not by the amount 

plaintiffs actually received from Nowakowski’s policy. Defendant also claimed that plaintiffs 

were not entitled to UIM benefits because Crispelli’s $2 million2liability limit exceeded plaintiffs’ 

$250,000 per-person liability limit. Defendant argued that, under provision 4(a) of the “Limits of 

Liability” subsection in plaintiffs’ UIM policy, Crispelli’s qualifies as an “organization which may 

be legally liable,” therefore, Crispelli’s $2 million policy limit relieved defendant’s obligation of 

paying UIM benefits to plaintiffs.

Plaintiffs responded, arguing that the terms of plaintiffs’ policy were ambiguous because 

the policy did not clearly articulate which of the two limits of liability apply: the $250,000 perperson limit or the $500,000 per-accident limit. Plaintiffs, citing Bogi v Citizens Ins Co of the 

Midwest, 427 F Supp 3d 954, 960-961 (WD Mich, 2019), argued that because the insurance policy 

did not specify which of the two liability limits applied, there were multiple reasonable 

interpretations of the insurance policy rendering it ambiguous. And, because ambiguous policies 

 

1 Plaintiffs’ claims against defendants Nowakowski and Crispelli’s were ultimately dismissed by 

stipulated order, as was Crispelli’s cross-claim against defendant Nowakowski.

2

In the trial court defendant asserted Crispelli’s policy had a $2 million limit, but on appeal 

suggests it is a $1 million limit.
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must be construed in favor of plaintiffs, as the insureds, the $500,000 per-accident liability limit 

should apply with respect to the determination whether Nowakowski’s vehicle was an 

underinsured vehicle. Plaintiffs also argued that Wilkie was distinguishable because in Wilkie the 

plaintiff’s coverage was reduced by “available” limits whereas, in this case, provision 4 of the 

“Limits of Liability” subsection reduced plaintiffs’ coverage based on the “sums paid or payable” 

to plaintiffs as the insureds. Therefore, it is not the policy limit that is relevant to a reduction;

rather, it is the amount actually paid or payable. Finally, plaintiffs argued that Crispelli’s $2

million policy limit was not applicable because—when reading provisions 3 and 4 of the “Limits 

of Liability” subsection together, only the limits of liability from organizations legally responsible 

for the underinsured motor vehicle reduce UIM benefits. Because Crispelli’s is not an organization 

legally responsible for Nowakowski’s motor vehicle, Crispelli’s $2 million policy limit could not 

be used to reduce plaintiffs’ recovery of UIM benefits.

Defendant replied, reasserting that the policy unambiguously states the $250,000 perperson liability limit applies. Defendant argued that the insurance policy’s repeated use of the 

phrase “insured person,” read together with the definition of underinsured motor vehicle, and the 

provisions in the “Limits of Liability” subsection, clearly show that the most plaintiffs could 

recover is $250,000 per person. However, because Nowakowski’s $300,000 policy limit is greater 

than plaintiffs’ $250,000 per-person limit, Nowakowski’s motor vehicle is not considered an 

underinsured vehicle and plaintiffs are not entitled to UIM benefits.

The trial court denied defendant’s motion for summary disposition, finding that defendant 

failed to explain why the $500,000 per-accident limit amount was not relevant or applicable when

the “Limits of Liability” subsection expressly referenced plaintiffs’ Insurance Policy Declaration 

Certificate, which lists both the $250,000 per-person and $500,000 per-accident limitations. In 

other words, the court noted, “plaintiffs are two individuals who would, ostensibly, be eligible for 

up to $250,000 in UIM benefits each for personal injury.” The court noted that Nowakowski’s 

policy limit was $300,000. But if both plaintiff’s proved $250,000 in bodily injury damages, then 

they would theoretically be entitled to $500,000 in UIM benefits, which would exceed the limits 

of Nowakowski’s policy but not plaintiffs’ UIM policy. Thus, the court held, because defendant’s 

policy is ambiguous, and ambiguities must be construed against defendant as the drafter of the 

UIM policy, plaintiffs’ interpretation prevailed and the $500,000 per-accident policy limit was 

applicable. The trial court rejected defendant’s argument that the holding in Wilkie applied here, 

noting that this case was not about whether the payment of a specific amount reduces the recovery 

under a UIM policy; rather, this case is about the applicable policy limits for purposes of 

determining whether there was an underinsured motor vehicle. Further, the trial court held, 

Crispelli’s $2 million policy limit was not applicable because that policy was not a no-fault policy 

that applied to Nowakowski’s motor vehicle under provision 4 of the “Limits of Liability” 

subsection. The court acknowledged that there were multiple possible interpretations of provision 

4; thus, the insurance policy was ambiguous and such ambiguity must be resolved in favor of 

plaintiffs. Because provision 3 limits liability to organizations legally responsible for the 

underinsured motor vehicle, provision 4 should be applied the same way and Crispelli’s policy 

limit would not reduce plaintiffs’ recovery of UIM benefits. In summary, the court concluded, 

defendant was not entitled to summary disposition. Defendant’s motion for reconsideration was 

denied and this appeal followed.
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II. STANDARD OF REVIEW AND APPLICABLE LAW

A trial court’s decision on a motion for summary disposition brought under MCR 

2.116(C)(10), which tests the factual sufficiency of the complaint, is reviewed de novo. Joseph v 

Auto Club Ins Ass’n, 491 Mich 200, 206; 815 NW2d 412 (2012). Documentary evidence 

submitted by the parties is reviewed in the light most favorable to the nonmoving party to 

determine whether a genuine issue of material fact exists for the jury to decide. Walsh v Taylor, 

263 Mich App 618, 621; 689 NW2d 506 (2004). If reasonable minds could differ on an issue, a 

genuine issue of material fact exists. Allison v AEW Capital Mgt, LLP, 481 Mich 419, 425; 751 

NW2d 8 (2008).

This case involves the proper interpretation of an UIM insurance contract. “The 

construction and interpretation of an insurance policy and whether the policy language is 

ambiguous are questions of law, which we also review de novo on appeal.” Dancey v Travelers 

Prop Cas Co of America, 288 Mich App 1, 7; 792 NW2d 372 (2010). More specifically, UIM 

coverage is not mandated by statute, and therefore, “the scope, coverage, and limitations of 

underinsurance protection are governed by the insurance contract and the law pertaining to 

contracts.” Mate v Wolverine Mut Ins Co, 233 Mich App 14, 19; 592 NW2d 379 (1998). 

Accordingly, judicial construction is not permitted with regard to unambiguous contracts; the plain 

and ordinary meaning of the language controls and the contract must be enforced as written as 

reflective of the parties’ intent as a matter of law. In re Smith Trust, 480 Mich 19, 24; 745 NW2d 

754 (2008); Rory v Continental Ins Co, 473 Mich 457, 464, 468; 703 NW2d 23 (2005). However,

when a contract’s words may reasonably be understood in different ways after consideration of the 

entire contract, the contract is considered ambiguous. Auto-Owners Ins Co v Seils, 310 Mich App 

132, 146; 871 NW2d 530 (2015). In other words:

If a fair reading of the entire contract of insurance leads one to understand that there 

is coverage under particular circumstances and another fair reading of it leads one 

to understand there is no coverage under the same circumstances the contract is 

ambiguous and should be construed against its drafter and in favor of coverage. 

[Raska v Farm Bureau Mut Ins Co of Mich, 412 Mich 355, 362; 314 NW2d 440 

(1982).]

III. UNDERINSURED MOTOR VEHICLE

Defendant argues that the trial court erroneously denied its motion for summary disposition 

because Nowakowski’s motor vehicle is not considered an underinsured motor vehicle under the 

unambiguous terms of plaintiffs’ UIM insurance policy. However, because the terms of plaintiffs’ 

UIM policy are ambiguous, we conclude that the trial court did not err in denying defendant’s 

motion for summary disposition.

A. ANALYSIS

Part III of plaintiffs’ no-fault insurance policy addresses uninsured and underinsured 

motorists coverages and defines an “underinsured motor vehicle” as:

[A] motor vehicle whose ownership, maintenance or use has resulted in bodily 

injury of an insured person and for which the sum of the Limits of Liability under 
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all bodily injury liability insurance policies, bonds or other security required to be 

maintained under law applicable to the driver or to the person or organization 

legally responsible for such vehicle and applicable to the vehicle is less than the 

limits of Underinsured Motorists Coverage provided the insured person at the time 

of the accident.

Thus, for plaintiffs to quality for UIM benefits, the sum of the limits of liability of Nowakowski’s 

insurance policy must be less than the limits of liability provided to plaintiffs as the “insured 

person[s].” Under plaintiffs’ insurance policy, “insured person(s)” are defined as: “you, if an 

individual, and a resident relative,” “any other person occupying your car,” the “principal 

named insured,” the “assigned driver,” “the spouse of the assigned driver,” and “an Other Name 

Insured.” Under this definition, both plaintiffs qualify as an “insured person,” therefore, the limits 

of liability apply to both plaintiffs.

Plaintiffs’ insurance policy explicitly states that there are two limits of liability for an 

insured person: a $250,000 per-person limit and a $500,000 per-accident limit. Because there are 

two stated limits, the determinative question is: which limit is considered when determining “the 

limits of Underinsured Motorists Coverage provided the insured person at the time of the 

accident” for purposes of the definition of an underinsured motor vehicle?

Defendant contends that the only reasonable interpretation of the policy is that the perperson limit rather than the per-accident limit applies. Specifically, defendant argues that because 

the definition of an underinsured motor vehicle and provision 1(a) under the “Limits of Liability” 

subsection both use the phrase “insured person,” this definitively implicates the $250,000 perperson limit. The Limits of Liability subsection provides:

1. The Limits of Liability for UNINSURED MOTORS COVERAGE and the 

Limits of Liability for UNDERINSURED MOTORISTS COVERAGE are shown 

on the Declaration Certificate and apply as follows:

a. the Limit of Liability for each person is the maximum Limit of Liability for all 

damages due to bodily injury to any insured person in any one accident. This 

limit includes any claim of other persons for damages for care and loss of services 

and society, wrongful death and survivor actions and derivation damages arising 

out of bodily injury.

b. subject to this limit for each person, the Limit of Liability for each accident is 

the maximum Limit of Liability for all damages due to bodily injury resulting from 

any one accident. This limit also includes any claims of other persons for damages 

for care and loss of services and society, wrongful death and survivor actions and 

derivative damages arising out of bodily injury.

Defendant’s argument, however, ignores that the definition of an “underinsured motor 

vehicle” explicitly uses the term “limits” in reference to UIM benefits coverage, which implies 

there is more than one applicable limit. And, the declarations page of plaintiffs’ policy clearly 

states the $250,000 per-person and $500,000 per-accident limits are both available to plaintiffs as 

insured persons. That is, the definition of “underinsured motor vehicle” uses the plural of the word 
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“limit” and states “the limits of Underinsured Motorists Coverage,” leading to a reasonable 

interpretation that—when there is more than one “insured person” in the accident, the $500,000 

per-accident limit applies when determining if the other vehicle involved in the accident was 

“underinsured.” As the trial court noted, in this case, if both plaintiffs proved $250,000 in bodily 

injury damages, defendant would be liable for the per-accident limit of $500,000, which far 

exceeded Nowakowski’s $300,000 policy limit. But if the definition of “underinsured motor 

vehicle” only referred to the per-person limit of $250,000—plaintiffs’ UIM policy would not be 

triggered despite the fact that Nowakowski’s policy would only cover $300,000 of those bodily 

injury damages. As the trial court also noted, defendant has failed to explain—even on appeal—

"why is the $500,000 per occurrence limit not the applicable ‘Limit of Liability,’ especially in a 

situation involving two plaintiffs who are both seeking bodily injury benefits?” Therefore, because 

the insurance policy does not explicitly state which limit applies when two or more insured persons 

are injured in the same accident for purposes of the “underinsured motor vehicle” definition, and 

the terms of plaintiffs’ insurance policy can reasonably be read to provide or deny coverage under 

the same set of circumstances, the policy is ambiguous, and ambiguous terms must be resolved in 

favor of plaintiffs as the insureds. See Seils, 310 Mich App at 146. Thus, the trial court properly 

rejected defendant’s argument and denied defendant’s motion for summary disposition.

IV. REDUCING THE LIMIT OF LIABILITY

Defendant next argues that the trial court erroneously found Crispelli’s $2 million policy 

limit is inapplicable to reduce plaintiffs’ UIM benefits. However, because it is reasonable to 

interpret the plain terms of plaintiffs’ insurance policy to exclude Crispelli’s as a qualifying 

organization or policy, the terms of plaintiffs’ insurance policy are ambiguous and we conclude 

that the trial court properly denied defendant’s motion for summary disposition.

A. ISSUE PRESERVATION

For the first time on appeal, defendant argues, under provision 4(b) of the “Limits of 

Liability” subsection, Crispelli’s $2 million policy limit is considered “any other policy” and 

reduces plaintiffs’ recovery to zero. “Michigan generally follows the ‘raise or waive’ rule of 

appellate review. Therefore, a litigant preserve[s] an issue for appellate review by raising it in the 

trial court.” Wells v State Farm Fire & Cas Co, 509 Mich 855, 856; 969 NW2d 67 (2022)

(quotation marks and citations omitted). Because defendant’s argument under provision 4(b) is an 

entirely separate argument raised for the first time on appeal, defendant has waived this argument 

for this Court’s review and is not entitled to relief. Id. at 856 n 6.

B. ANALYSIS

When interpreting an insurance policy, a two-step analysis is employed: “[F]irst, a 

determination of coverage according to the general insurance agreement, and, second, a decision 

regarding whether an exclusion applies to negate coverage.” Auto-Owners Ins Co v Harrington, 

455 Mich 377, 382; 565 NW2d 839 (1997). The insured bears the burden to prove coverage, while 

the insurer bears the burden of proving the applicability of an exclusion. Seils, 310 Mich App at 

146. “Clear and specific exclusions contained in policy language must be given effect.” Lee v 

Auto-Owners Ins Co, 218 Mich App 672, 676; 554 NW2d 610 (1996). “Exclusions are to be read 
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with the insuring agreement and independent of other exclusions.” Farm Bureau Mut Ins Co v 

Blood, 230 Mich App 58, 62; 583 NW2d 476 (1998).

Provision 3 under the “Limits of Liability” subsection of plaintiffs’ insurance policy states:

3. If the damages are caused by an underinsured motor vehicle, the most 

we will pay will be the lesser of:

a. the difference between the Limits of Liability of this coverage and the 

sum of the Limits of Liability under all bodily injury liability insurance policies, 

bonds or other security required to be maintained under law applicable to the driver 

or to the person or organization legally responsible for the underinsured motor 

vehicle and applicable to the underinsured motor vehicle; or

b. the difference between the amount of the insured person’s damages for 

bodily injury and the sum of the Limits of Liability under all bodily injury liability 

insurance policies, bonds or other security required to be maintained under law 

applicable to the driver or to the person or organization legally responsible for the 

underinsured motor vehicle and applicable to the underinsured motor vehicle. 

[Emphasis added.]

Provision 4 under the “Limits of Liability” subsection of plaintiffs’ insurance policy states, in 

relevant part:

4. Any amount payable under this Part will be reduced by:

a. any amount paid or payable by or on behalf of the owner or operator of

the uninsured motor vehicle or organization which may be legally liable;

b. any amount paid or payable under the Liability Insurance Coverage of 

this or any other policy;

* * *

A reduction under b. and c. above does not apply unless the amounts paid 

under Liability Insurance Coverage and Medical Payments Coverage cover the 

same elements of loss for which the insured person would receive Uninsured and 

Underinsured Motorists benefits.

Defendant first argues the trial court erred in disregarding Crispelli’s policy limit because 

it improperly found the terms of the provisions under the “Limits of Liability” subsection were 

ambiguous. Defendant claims under provision 4(a), Crispelli’s qualifies as an “organization which 

may be legally liable” to plaintiffs. “The word ‘or’ is a disjunctive term used to express a choice 

between alternatives.” Zwiker v Lake Superior State Univ, ___ Mich App ___, ___; ___ NW2d 

___ (2022) (Docket Nos. 355128; 355377; 357275); slip op at 12. Thus, to satisfy the requirements 

of the policy, it is not necessary to meet all possible alternatives, rather, it is enough to only satisfy 

one alternative. See Jesperson v Auto Club Ins Ass’n, 499 Mich 29, 35; 878 NW2d 799 (2016).
-8-

Provision 4(a) has four possible alternatives: (1) the amount payable will be reduced by 

any amount paid by or on behalf of the owner or operator of the uninsured motor vehicle; (2) the 

amount payable will be reduced by any amount payable by or on behalf of the owner or operator 

of the uninsured motor vehicle; (3) the amount payable will be reduced by any amount paid by or 

on behalf of the organization, which may be legally liable; and, (4) the amount payable will be 

reduced by any amount payable by or on behalf of the organization, which may be legally liable. 

Because alternatives one and two apply to uninsured motor vehicles, they are not relevant to this 

appeal. However, defendant asserts, under the fourth alternative, plaintiffs are precluded from 

recovery because Crispelli’s is an organization which may be legally liable to plaintiffs for 

furnishing alcohol to Nowakowski. Crispelli’s $2 million policy limit, the total amount payable 

on behalf of Crispelli’s to plaintiffs, is greater than both of plaintiffs’ limits of liability. Thus, 

applying defendant’s logic, Crispelli’s policy limit can preclude plaintiffs’ recovery.

However, while defendant’s contention that Crispelli’s policy can reduce plaintiffs’ 

recovery may be correct, provision 4(a) can also be read to exclude Crispelli’s liability limit. 

Defendant contends the use of the word “or” in provision 4(a) is disjunctive. But this Court has 

stated:

The popular use of “or” and “and” is so loose and so frequently inaccurate that it 

has infected statutory enactments. While they are not treated as interchangeable, 

and should be followed when their accurate reading does not render the sense 

dubious, their strict meaning is more readily departed from than that of other words, 

and one read in place of the other in deference to the meaning of the context. [Nolan 

v Dep’t of Licensing & Regulation, 151 Mich App 641, 649; 391 NW2d 424 (1986) 

(citations omitted).]

Therefore, depending on the context, it is reasonable to read the word “or” as the word “and.” Id. 

Applying that principle here, provision 4(a) would reduce any amount payable by: “any amount 

paid or payable on behalf of the owner or operator of the uninsured motor vehicle and organization 

which may be legally liable.” Under this interpretation, provision 4(a) would reduce defendant’s 

liability by the amount paid or payable by Crispelli’s, as an organization, for an uninsured motor 

vehicle. However, because Nowakowski’s vehicle was not an uninsured motor vehicle, but an 

underinsured motor vehicle, this interpretation excludes Crispelli’s insurance policy. As the 

definition section of the UIM policy states, an “uninsured” vehicle is not the same as an 

“underinsured” motor vehicle. Accordingly, the trial court properly rejected this argument.

Defendant additionally characterizes provisions 3 and 4 as exclusions, and claims the trial 

court erred in construing them together to find Crispelli’s liability policy is inapplicable. But 

defendant offers no evidence to support its contention. Plaintiffs’ insurance policy has a clearly 

labeled subsection titled “Exclusions” that immediately precedes, and is separate from, the “Limits 

of Liability” subsection. Based on the plain language of plaintiffs’ insurance policy, provisions 3 

and 4 are not exclusions as defendant claims, and do not need to be read independently. Further, 

defendant claims the trial court erred in reading provisions 3 and 4 together because they are 

unrelated and serve different purposes. But when determining coverage under an insurance policy, 
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pertinent provisions should be read in pari materia.

3

 Skanska USA Bldg Inc v MAP Mech 

Contractors, Inc, 505 Mich 368, 380 n 11; 952 NW2d 402 (2020). The Limits of Liability 

subsection determines the maximum amount of recovery plaintiffs may receive from defendant in 

any one accident. Provision 3 determines the maximum recovery for damages caused by an 

underinsured motor vehicle. Provision 4 reduces the amount recovered under provision 3. It is 

reasonable to conclude these provisions are related and serve the same purpose of determining the 

maximum amount of plaintiffs’ recovery. Therefore, the trial court did not err in reading 

provisions 3 and 4 together.

Because provisions 3 and 4 should be read together, the trial court did not err in finding 

Crispelli’s insurance policy cannot be used to preclude plaintiffs’ recovery. Provision 3 explicitly 

references liability insurance policies for “organizations legally responsible for the underinsured 

motor vehicle and applicable to the underinsured motor vehicle.” Provision 4(a) also references 

an “organization which may be legally liable.” Further, the insurance policy’s definition of an 

underinsured motor vehicle, which states, in relevant part: “[B]odily injury liability insurance 

policies. . . applicable to the driver or to the person or organization legally responsible for such 

vehicle and applicable to the vehicle.” As such, provision 4(a) should be read to apply only to 

organizations legally responsible for the motor vehicle because all three provisions are used to 

determine coverage for an underinsured motor vehicle, and thus may be construed together even 

if they do not explicitly reference each other. See Omne Fin, Inc v Shacks, Inc, 460 Mich 305, 

312; 596 NW2d 591 (1999). And because Crispelli’s is not an organization legally responsible for 

Nowakowski’s motor vehicle, the trial court properly excluded Crispelli’s insurance policy from 

provision 4(a).

In summary, the trial court did not err in denying defendant’s motion for summary 

disposition.

Affirmed.

/s/ Mark J. Cavanagh

/s/ Stephen L. Borrello

 

3

“Statutes in pari materia are statutes sharing a common purpose or relating to the same subject. 

They are construed together as one law, regardless of whether they contain any reference to one 

another.” Omne Fin, Inc v Shacks, Inc, 460 Mich 305, 312; 596 NW2d 591 (1999). Although the 

in pari materia doctrine typically applies to the construction of statutes, our Supreme Court 

construed the doctrine to also apply to the construction of insurance contracts in Skanska USA

Building.