(concurring). I concur with Judge Corrigan’s opinion, but write separately to explicate my position on the issue presented in light of my concurring vote in Marquis v Hartford Accident & Indemnity (On Remand), 195 Mich App 286; 489 NW2d 207 (1992).
In Marquis, the plaintiff was disabled from her employment because of an automobile injury. When she was medically able to return to work, she could not return to her employer because a permanent replacement had filled her position. The defendant no-fault insurer initially paid her work-loss benefits. The plaintiff then began working for a new employer. Her new job paid less than her preinjury position, and she voluntary resigned within two months. The issue presented to this Court in Marquis was whether the plaintiff was entitled to eighty-five percent of the difference in the compensation levels of her two jobs. This Court held that the defendant was responsible for eighty-five percent of the wage differential for the time after the plaintiff returned to work and after she quit her subsequent employment. Id.
I concurred with Judge Kelly’s opinion in Marquis .that the plaintiff was entitled to eighty-five percent of the difference in the compensation levels of her two jobs even for the time after she quit her second job, primarily for two reasons. First, the plaintiff had made a good-faith effort in finding another job. Second, the plaintiff in Marquis did not ask to be rewarded for quitting by seeking the difference between her preinjury wage and zero. Judge Kelly’s opinion stated that the plaintiff should not have the same work-loss benefits after she voluntarily quit her new job. However, the issue of mitigation of damages was not presented to this Court in Marquis. I believe that § 3107(b), MCL 500.3107(b); MSA 24.13107(b), requires the *741no-fault insurer to compensate the employee not for work she would have performed in the absence of insurance benefits (as Judge Corrigan postulates in the present case), but for loss of income due to the accident. Accordingly, compensating the plaintiff in Marquis with eighty-five percent of the difference in the compensation levels was consistent with the mandate of § 3107(b) that work loss consists of "loss of income from work an injured person would have performed” but for the accident.
In the present case, I concur with Judge Corrigan’s opinion because I believe that an employee losing a job under these circumstances has the duty to mitigate by seeking other employment. Although I agree with Judge Corrigan that reasonableness of mitigation is a question of fact, I would welcome standards (preferably from the Legislature) that might quell the onslaught of litigation regarding the "reasonableness” of mitigation our holding is bound to initiate.