(concurring). I agree with the majority that Eddie Thornton may not recover no-fault benefits for the injuries he sustained as a result of the armed robbery committed by a passenger in his taxicab.
I write separately because I am not persuaded that the standard stated in the opinion of the Court or any other word formulation this Court would adopt, construing the statutory phrase "arising out of the ownership, operation, maintenance or use of a motor vehicle as a motor vehicle,” MCL 500.3105(1); MSA 24.13105(1), would assist in correctly resolving future controversies.
i
As indicated in the opinion of the Court, the statutory phrase, "arising out of the ownership, operation, maintenance or use of a motor vehicle as a motor vehicle,” consists of two clauses.
The first clause, "arising out of the ownership, operation, maintenance or use of a motor vehicle,” was apparently adopted by the insurance industry *663long before the enactment of the no-fault acts, and, as noted in the commentary to the Uniform Motor Vehicle Accident Reparations Act, has been the subject of an enormous amount of litigation.1 The second clause is taken from the umvara.
All courts agree that some sort of causal connection between the injury and the ownership, maintenance, or use of the vehicle must be shown. In Kangas v Aetna Casualty & Surety Co, 64 Mich App 1; 235 NW2d 42 (1975), the Court of Appeals reviewed the pre-no-fault case law construing the first clause and concluded, as set forth in the opinion of the Court, that the causal relationship must be "more than incidental, fortuitous or but for.”
The opinion of the Court suggests that the Ran-gas formulation accurately reflects the connection between the injury and the motor vehicle contemplated by the statutory phrase "arising out of the ownership, operation, maintenance or use of a motor vehicle as a motor vehicle” and appears to adopt that formulation as the test for construing both the first and the second clauses.
This Court has not, heretofore, articulated a standard for either the first or second clause.2 The case law and commentary yield a panoply of word formulations for the first clause.
Appleman states, "The words 'arising out of’ . . . are ordinarily understood to mean originating from, incident to, or having connection with the *664use of the vehicle.”3 Appleman offers a summary of the pre-no-fault cases, stating:
Accordingly, three rather interesting rules have been set up to determine the insurer’s liability: 1. The accident must have arisen out of the inherent nature of the automobile, as such; 2. The accident must have arisen within the natural territorial limits of an automobile, and the actual use, loading, or unloading must not have terminated; 3. The automobile must not merely contribute to cause the condition which produces the injury, but must, itself, produce the injury.[4]
An annotation states that the "clause 'arising out of’ has been held to mean 'originating from,’ 'growing out of,’ or 'flowing from.’ ”5
Another treatise discusses the continuing viability of four tests for determining the sufficiency of the causal link: "proximate cause,” "causal connection,” "involvement,” and "but for.”6
We hesitate to adopt any word formulation — the test stated in Kangas, or offered by Appleman, or any other — as an accurate and complete embodiment of the meaning of the first clause as applied in varying fact situations.
ii
The second clause of the statutory phrase requires that the injury "aris[e] out of the . . . use of *665a motor vehicle as a motor vehicle.” (Emphasis supplied.)
Kangas concerned the first clause, not the second clause. Assuming that Kangas correctly reviewed and summarized the pre-no-fault case law construing the automobile policy language set forth in the first clause of the statutory definition, that may not bear on the correct construction of the second clause.
To adopt the case law construing the first clause as the test for the second clause would tend to eliminate the second clause as a further qualification or limitation.
The commentary to the umvara indicates that the second clause might or should be construed as a further limitation: ”[T]he requirement that use of the motor vehicle be 'as a motor vehicle’ qualifies the term so that both the tort exemption and the availability of basic reparation benefits are more nearly limited to activities whose costs should be allocated to motoring as part of an automobile insurance package.”7 (Emphasis supplied.)
In the instant case, the taxi was like a convenience store. Thieves recognize that taxis, like convenience stores, are potential sources of cash because taxi drivers generally carry cash to operate their businesses. I would, to decide this case, conclude that an assault on a person who generally carries cash to conduct business is not a risk associated with motoring, but is a risk of such a business. That risk of a cash business is not a risk whose cost should be allocated to motoring.
in
While it would be desirable to state a specific *666test to guide bench and bar, the authors of the umvara, in adding the second clause, "as a motor vehicle,” said that they had not found it "possible to define the general concept more specifically, so borderline cases are left to the courts . . . .”8
Although the injuries inflicted on Thornton do not come within the intendment of the no-fault act, there might be a difference between the assault in the instant case and some other assaults in respect to the use of automobiles that might justify providing for recovery in other cases while recovery is denied in this case.
Suppose a driver of an automobile loses control of the automobile after being shot by a robber and collides with another vehicle; in such a case no-fault benefits might be awarded. Suppose an automobile breaks down or runs out of gas in the wintertime and the driver suffers frostbite or freezes to death; in such a case also no-fault benefits might be recoverable. If so, might not they also be recoverable if the person whose automobile breaks down or runs out of gas is assaulted walking to or from the gas station?
There must indeed be a causal connection between the injury and the use of the automobile as an automobile. It is not sufficient that an automobile was the physical situs of an injury. The test adopted by the majority from Kangas, that the causal relationship be "more than incidental, fortuitous or but for,” might be read as barring recovery in a future case that is within the intendment of the no-fault act because the risk is one *667associated with motoring. A word formulation adequate to resolve correctly future controversies has not as yet evolved.
Archer, J., concurred with Levin, J.14 ULA 56, § 1.
In Miller v Auto-Owners Ins Co, 411 Mich 633; 309 NW2d 544 (1981), this Court sought to reconcile the exclusion for parked vehicles in § 3106 with the provision for benefits in § 3105(1). The opinion of the Court explained that the exceptions to the parking exclusion "describef] an instance where . . . [the vehicle’s] involvement in an accident is nonetheless directly related to its character as a motor vehicle,” id. at 640. The opinion did not suggest a word formulation or standard for the first or the second clause of § 3105(1).
6B Appleman, Insurance Law & Practice (Buckley ed), § 4317, pp 360-363.
Id., pp 367-368.
Anno: Automobile liability insurance: What are accidents or injuries "arising out of ownership, maintenance, or use” of an insured vehicle, 89 ALR2d 150. Similarly, see 12 Couch, Insurance, 2d, § 45:61, p 294.
Farrell, Hartig & Koatz, No Fault & Uninsured Motorist Automobile Insurance, § 9.20, pp 9-Í7 to 9-31.
See n 1 supra, pp 55-56.
Id., p 56.