OPINION

Viviano, J.

At issue in this case is whether plaintiff, Daniel Kemp, is entitled to personal protection insurance (PIP) benefits under the no-fault act1 for injuries he allegedly sustained while unloading personal belongings from his parked vehicle.2 We hold that plaintiff created an issue of fact regarding whether he satisfied the parked motor vehicle exception in MCL 500.3106(1)(b) and the corresponding causation requirement. We also hold as a matter of law that plaintiff satisfied the transportational function requirement. Therefore, we reverse the judgment of the Court of Appeals and remand this case to the trial court for further proceedings not inconsistent with this opinion.

I. FACTS AND PROCEEDINGS

On September 15, 2012, after plaintiff finished working, he placed his briefcase, overnight bag, thermos, and lunch box on the floor behind the driver's seat of his 2010 Chevy Silverado 1500 extended cab truck. He then drove home. When he arrived, he parked in his driveway, stepped out of the vehicle, and went to retrieve his belongings. Plaintiff opened the rear door, reached into the vehicle for his belongings, and sustained an injury as he was lowering them from the vehicle.

Subsequently, plaintiff filed suit against his auto insurer, defendant Farm Bureau General Insurance Company of Michigan, seeking no-fault benefits under § 3106(1)(b). Defendant moved for summary disposition under MCR 2.116(C)(10), arguing that plaintiff was not entitled to no-fault benefits because (1) his injury did not arise out of the ownership, operation, maintenance, or use of the parked motor vehicle as a motor vehicle, (2) his injury did not meet the parked motor vehicle exception in § 3106(1)(b), and (3) his injury did not have a causal relationship to the parked motor vehicle that was more than incidental, fortuitous, or but for. In response, plaintiff asked the trial court to deny defendant's motion and to grant plaintiff judgment under MCR 2.116(I)(2).3 The trial court granted defendant's motion.

Plaintiff appealed, and the Court of Appeals affirmed the trial court's judgment in a split decision.4 The Court of Appeals majority concluded that plaintiff's "injury had nothing to do with `the transportational function' of his truck."5 According to the Court, "the removal of personal effects from a parked vehicle ... cannot be said to result from some facet particular to the normal functioning of a motor vehicle" because similar movements routinely occur in other places.6 Rather, the majority reasoned, plaintiff's vehicle was used as a "storage space for his personal items" and was "merely the site" of the injury.7

Dissenting, Judge BECKERING concluded that plaintiff had satisfied the parked motor vehicle exception set forth in § 3106(1)(b).8 The dissent further concluded that plaintiff had satisfied the transportational function requirement because "it is axiomatic that when one travels in a vehicle, one will take personal effects along for the ride and will seek to unload those personal effects when the drive is finished."9 Finally, the dissent reasoned that "plaintiff's injury had a direct causal relationship to the parked vehicle" because it was the act of retrieving his personal effects from his vehicle that caused his injury.10

Plaintiff then sought review in this Court, and we ordered oral argument on plaintiff's application, directing the parties to address

II. STANDARD OF REVIEW

We review de novo a trial court's decision to grant a motion for summary disposition under MCR 2.116(C)(10).12 MCR 2.116(C)(10) provides that summary disposition is appropriate when, "[e]xcept as to the amount of damages, there is no genuine issue as to any material fact, and the moving party is entitled to judgment or partial judgment as a matter of law." In determining whether there is a genuine issue as to any material fact, we consider the evidence in the light most favorable to the nonmoving party.13 "[W]here there is no dispute about the facts, the issue whether an injury arose out of the use of a vehicle is a legal issue for a court to decide and not a factual one for a jury."14

Issues of statutory interpretation are also reviewed de novo.15 When interpreting statutes, our goal is to give effect to the Legislature's intent, focusing first on the statute's plain language.16 "In so doing, we examine the statute as a whole, reading individual words and phrases in the context of the entire legislative scheme."17 "When a statute's language is unambiguous, the Legislature must have intended the meaning clearly expressed, and the statute must be enforced as written."18

III. ANALYSIS

A. LEGAL BACKGROUND

"The Michigan no-fault insurance act requires a no-fault automobile insurer to provide first-party injury protection for certain injuries related to a motor vehicle...."19 The no-fault act's initial scope of coverage for PIP benefits is set forth in MCL 500.3105(1), which provides that under "personal protection insurance an insurer is liable to pay benefits for accidental bodily injury arising out of the ownership, operation, maintenance or use of a motor vehicle as a motor vehicle, subject to the provisions of this chapter." However, when an injury involves a parked motor vehicle, coverage is generally excluded unless the claimant demonstrates that one of three statutory exceptions applies.20 Plaintiff claims that he is entitled to PIP benefits under the parked motor vehicle exception contained in the second clause of § 3106(1)(b), which provides:

This Court has provided a three-step framework to analyze coverage of injuries related to parked motor vehicles.22 First, the claimant must demonstrate that his or her "conduct fits one of the three exceptions of subsection 3106(1)."23 Second, the claimant must show that "the injury arose out of the ownership, operation, maintenance, or use of the parked motor vehicle as a motor vehicle[.]"24 Finally, the claimant must demonstrate that the "injury had a causal relationship to the parked motor vehicle that is more than incidental, fortuitous, or but for."25 We analyze each of these requirements in turn.

B. STEP ONE: PARKED MOTOR VEHICLE EXCEPTION IN § 3106(1)(b)

We must first determine whether plaintiff's conduct falls within the parked motor vehicle exception contained in the second clause of § 3106(1)(b), which provides coverage when "the injury was a direct result of physical contact with ... property being lifted onto or lowered from the vehicle in the loading or unloading process."26

In this case, plaintiff established a question of fact concerning whether he was injured as he lowered his briefcase, overnight bag, thermos, and lunch box (all of which were bundled together) from his vehicle to the ground during the unloading process. Those items are "property" because they are things "owned or possessed" by plaintiff.27 And plaintiff testified that he was in physical contact with his property and lowering it from the vehicle when he sustained the injury.

That leaves only the question whether a reasonable jury could find that plaintiff's injury was the "direct result" of this physical contact with the property. At an earlier stage of this case, defendant argued that the statutory phrase "direct result" means that the injury must be "due to" physical contact with the property — a position that the dissent now advances. We agree. Plaintiff must show that his injury was caused by contact with the property being loaded or unloaded.28

Here, plaintiff testified: "I leaned in the vehicle, picked up my items, brought them outside as I twisted to set them down. That's when I heard bang, stuff fell to the ground, I fell in the truck." The dissent contends, in essence, that this testimony establishes only a temporal, rather than a causal, relationship between plaintiff's contact with the property and his injury and is therefore insufficient to create a jury question. It is true, of course, that plaintiff did not himself testify as to causation, but we do not believe it follows that a jury could not reasonably infer causation from plaintiff's testimony and other evidence in the record.29

We can cite, and indeed the dissent also cites, several cases in which a plaintiff's injury was caused (or alleged to be caused) by the kinetic energy, weight, or some other physical property associated with the thing being loaded or unloaded from a parked motor vehicle.30 Whether, in this case, plaintiff's property was of sufficient size and weight to cause plaintiff's injury is, in our view, an issue for the jury to decide — unless we could conclude, as a matter of law, that it could not have caused the injury alleged.31 We believe plaintiff's bundled-together briefcase, overnight bag, thermos, and lunch box clears this threshold.32

Accordingly, plaintiff established a question of fact as to whether his injury falls within the parked motor vehicle exception in the second clause of § 3106(1)(b) because it "was a direct result of physical contact with ... property being lifted onto or lowered from the vehicle in the loading or unloading process."

C. STEP TWO: TRANSPORTATIONAL FUNCTION REQUIREMENT

Next, we must determine whether plaintiff has met the transportational function requirement.33 In McKenzie, this Court discussed this requirement as follows:

The Court concluded that "whether an injury arises out of the use of a motor vehicle `as a motor vehicle' under § 3105 turns on whether the injury is closely related to the transportational function of motor vehicles."35 To answer this question, we must examine the activity the plaintiff was engaged in at the time of the injury.36

In this case, it is undisputed that plaintiff was injured while unloading personal items from his vehicle upon arrival at his destination. We believe the conveyance of one's belongings is also closely related to — if not an integral part of — the transportational function of motor vehicles.37 Lending support to our interpretation of the statutory language is that "the dictionary definition of `vehicle' is `any device or contrivance for carrying or conveying persons or objects, [especially] over land or in space....'"38 We have little difficulty concluding that a person who is engaged in the activity of unloading his or her personal effects from a vehicle upon arrival at a destination is using the vehicle for its transportational function, i.e., for the conveyance of persons or objects from one place to another.

The Court of Appeals, in reaching a contrary conclusion, relied heavily on Shellenberger v. Ins. Co. of North America, stating as follows:

We find Shellenberger's reasoning to be troubling for the following reasons. First, while it appropriately focuses on the activity the plaintiff was engaged in at the time of the injury — for example, moving a briefcase in Shellenberger and unloading personal effects from a parked vehicle in this case — the proper inquiry under McKenzie is whether that activity was closely related to the vehicle's transportational function.40 There is no requirement that the activity at issue "result from" the vehicle's transportational function — that requirement would confuse the transportational function and causation inquiries. And, more importantly, Shellenberger erroneously conflates transportational function with "some facet particular to the normal functioning of a motor vehicle."41 Contrary to Shellenberger's suggestion, Thornton does not require that the type of movements made or the injuries suffered be unique to motor vehicles or that they may only occur in a motor vehicle.42 Instead, as noted above, the question at this stage is simply whether the activity plaintiff was engaged in at the time of the injury was closely related to the vehicle's transportational function. That the injury could have occurred elsewhere is of no moment.

This is not the first time we have rejected Shellenberger's analysis. In McCarthy v. Allstate Ins. Co., the Court of Appeals, after quoting the same passage from Shellenberger, observed that "the movements that [the claimant] made to lift [a box of pasties] — twisting, turning, reaching behind her, attempting to lift the box — could have occurred in her home, her place of work, and `countless other settings where no-fault insurance does not attach.'"43 The McCarthy Court held that the causation requirement was not satisfied, stating as follows:

On appeal, we reversed the Court of Appeals' analysis and held that the "plaintiff established a causal link between her injury and the motor vehicle. The box of pasties she was unloading from her car snagged on the front seat and she hurt her back trying to free the box up to lift it out."45 Having rejected Shellenberger's analysis on two separate occasions, we now overrule it to the extent that it is inconsistent with our opinion today.

We hold that unloading property from a vehicle upon arrival at a destination constitutes use of a motor vehicle as a motor vehicle and satisfies the transportational function requirement.46 In the present case, plaintiff testified that he sustained an injury while unloading his belongings from his vehicle upon arriving at his house. As a result, plaintiff satisfied the transportational function requirement as a matter of law.

D. STEP THREE: CAUSAL RELATIONSHIP

Finally, we must consider whether "the injury had a causal relationship to the parked motor vehicle that [was] more than incidental, fortuitous, or but for."47 In Thornton, we adopted the following causation test set forth in Kangas v. Aetna Casualty & Surety Co.:

After noting "a significant difference between the contractual language construed in Kangas — `arising out of the use of a motor vehicle' — and the statutory language at issue [in Thornton]: `arising out of the use of a motor vehicle as a motor vehicle,"49 we concluded that there can be no recovery of no-fault PIP benefits unless the causal connection between the injury and the use of a motor vehicle as a motor vehicle "is more than `but for,' incidental, or fortuitous."50

In Thornton, as noted previously, we explained that "`[e]ach of the exceptions to the parking exclusion ... describes an instance where, although the vehicle is parked, its involvement in an accident is nonetheless directly related to its character as a motor vehicle.'"51 We have already concluded above that plaintiff created an issue of fact that his conduct in unloading his vehicle upon arrival at his destination falls within the parked motor vehicle exception contained in the second clause of § 3106(1)(b). And we have concluded that, as a matter of law, plaintiff was using his vehicle as a motor vehicle, i.e., for a transportational purpose, when he was unloading his property from it. All that is left, then, is to determine whether plaintiff's injury had a causal relation to his conduct in unloading his vehicle that was more than incidental, fortuitous, or but for.52

We believe that plaintiff's injury — suffered while he was unloading his property from his vehicle upon his arrival home — was foreseeably identifiable with the normal use of the vehicle. The parked motor vehicle exception contained in the second clause of § 3106(1)(b) has its own causation component. See MCL 500.3106(1)(b) (stating that "the injury was a direct result of physical contact") (emphasis added). Having already concluded that plaintiff has established a question of fact regarding whether he met this causation requirement, we also conclude that he has raised a question of fact regarding whether his injury had a causal relation to the use of a motor vehicle as a motor vehicle that was more than incidental, fortuitous, or but for.53

IV. CONCLUSION

We hold that plaintiff created an issue of fact regarding whether he satisfied the parked motor vehicle exception in § 3106(1)(b) and the corresponding causation requirement of the three-step framework used to analyze PIP coverage for injuries related to parked motor vehicles. And we hold as a matter of law that plaintiff satisfied the transportational function requirement. Therefore, we reverse the judgment of the Court of Appeals and remand this case to the trial court for further proceedings not inconsistent with this opinion.

Bridget M. McCormack, Richard H. Bernstein, Joan L. Larsen, JJ., concur.

Zahra, J. (dissenting).

In this no-fault action arising from plaintiff's interaction with items in a parked vehicle, the majority concludes "that plaintiff created an issue of fact regarding whether he satisfied the parked motor vehicle exception in MCL 500.3106(1)(b) and the corresponding causation requirement."1 The majority also concludes "as a matter of law that plaintiff satisfied the transportational function requirement."2 I respectfully dissent. I would decide this case on the basis of MCL 500.3106(1)(b) alone and hold that plaintiff has failed to establish a genuine factual basis from which to conclude that "the injury was a direct result of physical contact with ... property being lifted onto or lowered from the vehicle in the loading or unloading process."3

Further, I would take this opportunity to reexamine Putkamer v. Transamerica Ins. Corp. of America'4 and its progeny. In my view, the causation prong of Putkamer's analytical framework does not find its origin in the plain language of MCL 500.3106, and caselaw addressing the parked vehicle provision, over the years, has drifted well beyond the language of the no-fault act, MCL 500.3101 et seq. This case makes clear that the third prong, i.e., the causation prong, of Putkamer's general test cannot apply to injuries arising from parked vehicles under MCL 500.3106(1)(b). And because this error of statutory interpretation will often reoccur, the most prudent action at this time would be to grant plaintiff's application and, with the benefit of full briefing and argument, reexamine the operation of MCL 500.3106 and the vitality of Putkamer. I believe that failing to correct the misinterpretation of MCL 500.3106 will "impose far more injury upon the judicial process than any effect associated with our decision to apply the policy decisions of the Legislature instead of the policy decisions of this Court...."5

I. MCL 500.3106(1)(b)

Under Michigan's no-fault insurance act and in regard to this case, "[a]ccidental bodily injury does not arise out of the ownership, operation, maintenance, or use of a parked vehicle as a motor vehicle unless," as set forth in MCL 500.3106(1)(b), "the injury was a direct result of physical contact with ... property being lifted onto or lowered from the vehicle in the loading or unloading process."6 In this case, plaintiff sustained injury while unloading personal belongings from his parked vehicle. He testified: "I leaned in the vehicle, picked up my items, brought them outside as I twisted to set them down. That's when I heard bang, stuff fell to the ground, I fell in the truck." For purposes of this appeal, I accept the majority's characterization of plaintiff's testimony "that he was in physical contact with his property and lowering it from the vehicle when he sustained the injury."7

Regardless of whether the term "property" is afforded its plain meaning as the majority posits8 or its contextual meaning of "cargo or freight" as first suggested by defendant on appeal in this Court,9 this term is not the focal point of this case. The disputed statutory language is whether "the injury was a direct result of physical contact with ... property being lifted onto or lowered from the vehicle in the loading or unloading process."10 On this point, the majority concludes that plaintiff's contact with his briefcase, overnight bag, thermos, and unfoldable lunch bags while unloading them from his vehicle creates a genuine issue of material fact as to whether this property caused the injury alleged.11 In support of its conclusion, the majority relies on caselaw that, as summarized by the majority, requires that "plaintiff's injury [be] caused (or alleged to be caused) by the kinetic energy, weight, or some other physical property associated with the thing being loaded or unloaded from a parked motor vehicle."12 In this case, while plaintiff was in physical contact with the property, there is no evidence to indicate that physical contact with the property — the "kinetic energy, weight, or some other physical property associated with the thing being loaded or unloaded" — caused the injury, rather than the twisting action of placing the property on the ground.13

In my view, plaintiff's testimony that he was in physical contact with the property he was removing from his truck when he sustained the injury does not establish that "the injury was a direct result of physical contact with ... property...."14 Plaintiff's testimony indicated that the injury occurred while he was turning and twisting to set down his personal items. This suggests that the act of unloading the property caused the injury, rather than plaintiff's contact with the property. While plaintiff testified that he was unloading his "briefcase, overnight bag, thermos[, and] ... unfoldable lunch bags," all of which were bound together, he made no assertion that any or all of these items caused his injury.15 Therefore, the record presented to this Court does not support the conclusion that there exists a genuine issue of material fact regarding whether plaintiff's injury was a "direct result" of his physical contact with the property he was unloading from his truck.16

The majority fails to attach independent meaning to the phrase "direct result." That is, the majority suggests that a plaintiff establishes that his or her injury was a "direct result" merely by presenting evidence that the plaintiff was injured while in physical contact with property that he or she was loading or unloading from a vehicle. But the statute plainly requires that the injury be a direct result of physical contact with property that is being loaded or unloaded. A person struck by lightning while in physical contact with property that he or she is loading or unloading cannot be said to be injured as a direct result of physical contact with that property. In both legal and common parlance, the word "direct" in this context means to be "[f]ree from extraneous influence; immediate,"17 and "result" commonly means "consequence, effect, or conclusion."18 Reading these terms together, one gleans that a plaintiff's injury must have arisen from an uninfluenced and immediate consequence of physical contact with property being lifted onto or lowered from the vehicle in the loading or unloading process. But, again, plaintiff has presented no evidence at all that physical contact with his property caused his injury.

Perhaps if the statute provided instead that coverage is afforded for an injury that in any way results from the loading or unloading process, I would be inclined to agree with the majority. But it does not, and the majority has not identified any evidence that plaintiff's injury was the direct result of physical contact with his property. Even plaintiff's expert could only conclude that plaintiff's "calf and low back injuries arose out of the process of unloading the items as [plaintiff] described...."19 Simply put, an injury arising out of the process of unloading items from a vehicle does not establish that "the injury was a direct result of physical contact with ... property...."20

There exists published caselaw from the Court of Appeals consistent with my interpretation of MCL 500.3106(1)(b). For instance, in Celina Mut. Ins. Co. v. Citizens Ins. Co.,21 the Court of Appeals sustained a claim under MCL 500.3106(1)(b) when, in the process of loading a semitrailer, "the crane operator accidentally knocked a bundle [of steel tubing] off a previously stacked pile, and that bundle rolled into and injured [the claimant]."22 Another example is Adanalic v. Harco Nat'l Ins. Co.,23 in which the claimant was seriously injured while unloading a pallet from a truck onto a semitrailer". Specifically, while the claimant "was pulling the pallet with a belt," "[t]he ramp connecting the trailer and the [truck] collapsed, which caused the pallet to fall to the ground, which, in turn, caused [the claimant] to fall to the ground."24 The panel noted that "the statute does not require that the property, itself, inflict the injuries. It only requires that the injuries directly result from physical contact with the property."25 Therefore, reasoned the panel, "the statute is satisfied... where [the claimant's] physical contact with the pallet caused him to fall to the ground, directly resulting in his injuries."26 In sum, these cases were sustained because the property directly contributed to the injury.27

II. PUTKAMER v. TRANSAMERICA INS. CORP. OF AMERICA

As previously mentioned, I would take this opportunity to reexamine Putkamer28 and its progeny. In my view, there is little question that the third prong of Putkamer's general test cannot apply to injuries arising from parked vehicles under MCL 500.3106(1)(b).

In Putkamer, the "plaintiff was getting into her vehicle on the driver's side, [and] she fell on the ice and was injured."29 Citing our decision in Winter v. Auto Club of Mich.,30 we explained that "[w]here the motor vehicle is parked, the determination whether the injury is covered by the no-fault insurer generally is governed by the provisions of subsection 3106(1) alone."31 We further explained that "[t]here is no need for an additional determination whether the injury is covered under subsection 3105(1)."32 Though it seems clear from that language that Putkamer embraced the proposition that MCL 500.3105(1) is not controlling in parked vehicle cases,33 the Court then explained that the "underlying policy of the parked motor vehicle exclusion ... is to ensure that an injury that is covered by the no-fault act involves use of the parked motor vehicle as a motor vehicle."34

This purported underlying policy was first explained in Miller v. Auto-Owners Ins. Co.,35 which involved a claim for accidental bodily injury arising out of the maintenance of a motor vehicle, although the vehicle was parked at the time of the accident. Rather than addressing the relevant statutory text, the Court in Miller engaged in "an assessment of the respective policies appearing from the requirement of coverage in § 3105(1) and the exclusion from that required coverage for parked vehicles in § 3106 as they bear upon the scope of coverage intended by the Legislature."36 The Court opined that the policy underlying the parked vehicle exclusion was that

The Miller Court held that because "[t]he policies underlying § 3105(1) and § 3106 thus are complementary rather than conflicting," "[c]ompensation is thus required by the no-fault act without regard to whether [the plaintiff's] vehicle might be considered `parked' at the time of injury."38 By adopting Miller's dubious assertions of "underlying policies" of the no-fault act,39 the Putkamer Court opened itself to further departure from the textual basis of the law. While there is some textual basis under MCL 500.3106(1) to require that the injury be "`directly related' to the vehicle's character as a motor vehicle,"40 i.e., "parked vehicle as a motor vehicle,"41 there is no basis to conclude "that subsection 3106(1), like subsection 3105(1), requires that, in order to recover, the injury must have a causal relationship to the motor vehicle that is more than incidental, fortuitous, or but for."42

Putkamer broadly held that

In my opinion, the Putkamer test does not bear sufficient resemblance to the actual statutory text at issue. MCL 500.3106(1) provides that:

I agree with Putkamer to the extent that it concludes that a plaintiff who meets an exception contained in MCL 500.3106(1)(a) to (c) that arises out of the ownership, operation, maintenance, or use of a parked vehicle as a motor vehicle has established an accidental bodily injury. But, because the Legislature included a causal component in MCL 500.3106(1)(b), i.e., "direct result," I see no statutory support for the proposition that a claimant must additionally establish that the injury had a causal relationship to the parked motor vehicle that is more than incidental, fortuitous, or but for. At a minimum, I would limit Putkamer and its progeny and clarify that the third prong of Putkamer's general test does not apply to injuries arising from parked vehicles under MCL 500.3106(1)(b). With that said, I believe the most prudent action at this time would be to grant plaintiff's application and, with the benefit of full briefing and argument, reexamine the operation of MCL 500.3106 and the vitality of Putkamer.

Stephen J. Markman, C.J., Kurtis T. Wilder, J., agrees.