Compensation for replacement services in a no fault third party benefits action

In Johnson v Recca, __ Mich App __ (#294363, 4/5/2011) the Court of Appeals held that expenses for replacement services rendered more than three years after the date of the motor vehicle accident are compensable damages in third-party actions because replacement services expenses are “allowable expenses,” and because MCL 500.3135(3)(c) did not abolish tort liability for “[d]amages for allowable expenses . . . in excess of the daily, monthly, and 3-year limitations contained in [sections 3107 to 3110],”.