Where a complaint for personal injury protection benefits under the no-fault act was dismissed when the plaintiff failed to appear on the second day of trial, the trial court abused its discretion by not explicitly evaluating available lesser sanctions on the record, so a remand is necessary.
Plaintiff Kristopher Whitaker’s first-party PIP claim arose out of a May 24, 2020, two-vehicle accident which occurred at 2:30 a.m. at the intersection of Hayes and Fairmont in Detroit. The 2005 Jeep Grand Cherokee plaintiff was a passenger in was travelling when it struck a 2020 Jeep Gladiator. In his June 18, 2020, amended application