We initially note that defendant's argument that this Court should look to the UCC for the definition of written instrument is without merit. Based upon these definitions, we find that an insurance policy or contract is clearly a written instrument. It is, in essence, a contract, reduced to writing, which evidences the formal agreement between the parties. Again, we disagree. Therefore, although the two provisions provide similar redress, they do not render each other meaningless.
Constitutional issues are questions of law.
Issues of law are reviewed de novo on appeal. The equal protection clause of the Michigan Constitution guarantees require that people under similar circumstances will be treated alike. Equal protection does not require that persons under different circumstances be treated the same. Under traditional equal protection analysis, a statute must be sustained if the classification is rationally related to a legitimate governmental interest. Bissell , supra .