1991); McAdoo v. United States, 607 F. Supp. 788 (E.D.Mich. 1984); Zotos v. United States, 654 F. Supp. 36 (E.D.Mich. 1986). In Caruana v. United States, an unpublished 1985 opinion by the late Honorable Philip Pratt of the United States District Court for the Eastern District of Michigan (Civil No. 81-71396, attached to the government's June 15, 1993, brief), the United States Postal Service was sued under the Federal Tort Claims Act for damages arising from an auto-related accident.

Thus, Michigan's No-Fault Act does not directly apply to the United States government, but the statute still governs the outcome pursuant to the FTCA. See Westfield Cos. v. United States, 858 F.Supp. 658, 661 (E.D.Mich. 1993) ("This court finds Michigan's No-Fault Act to be applicable to the United States of America."); Zotos v. United States, 654 F.Supp. 36, 38 (E.D.Mich. 1986) (citing Lee v. Detroit Auto. Inter-Ins. Exch., 412 Mich. 505, 315 N.W.2d 413, 416 (1982)) (noting that nonregistered vehicles are covered by Michigan's No-Fault Act).

By contrast, the state and federal district courts in Michigan have consistently held that although the federal government is exempt from the registration provisions contained in the Michigan no-fault act, non-registered vehicles are still "covered by the No-Fault Act." Zotos v. United States, 654 F. Supp. 36, 37-38 (E.D.Mich. 1986). However, the Kentucky MVRA expressly exempts the federal government from the security provisions.