(dissenting). I disagree with the majority’s position that it is only necessary that the automobile be the occasion of the injury and no causal connection need be shown. In order to support this assertion, reliance is made upon the interpretation of language in the Worker’s Disability Compensation Act.
It is not necessary to go to worker’s compensation law to ascertain the meaning of the "arising out of’ term here for there is an abundance of case law directly on point. See, Anno: Automobile *221liability insurance: what are accidents or injuries "Arising Out of Ownership, Maintenance or Use” of insured vehicle, 89 ALR2d 150, 154, wherein the following statement is made:
"It is well settled that a causal relation or connection must exist between an accident or injury and the ownership, maintenance, or use of a vehicle in order for the accident or injury to come within the meaning of the phrase 'arising out of the ownership, maintenance or use’ of a vehicle.”
Moreover, worker’s compensation law applies essentially a "but for” test to determine whether an injury is sufficiently related to the employment relationship to be compensable. Nemeth v Michigan Building Components, 390 Mich 734, 736; 213 NW2d 144 (1973). Such an approach in automobile insurance cases was expressly rejected in Kangas v Aetna Casualty & Surety Co, 64 Mich App 1, 17; 235 NW2d 42 (1975):
"In summary, we conclude that while the automobile need not be the proximate cause of the injury, there still must be a caused connection between the injury sustained and the ownership, maintenance or use of the automobile and which causal connection is more than incidental, fortuitous or but for.”
I also believe the majority has failed to deal properly with the relationship between §§ 3105 and 3106 of the no-fault act. Section 3105 provides the general requisite for liability:
"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 *222provisions of this chapter.” MCL 500.3105(1); MSA 24.13105(1).
Where the insured vehicle is parked there are additional criteria which must be met:
"Accidental bodily injury does not arise out of the ownership, operation, maintenance or use of a parked vehicle as a motor vehicle unless any of the following occur:
"(a) The vehicle was parked in such a way as to cause unreasonable risk of the bodily injury which occurred.
"(b) The injury was a direct result of physical contact with equipment permanently mounted on the vehicle, while the equipment was being operated or used or property being lifted onto or lowered from the vehicle in the loading or unloading process.
"(c) The injury was sustained by a person while occupying, entering into or alighting from the vehicle.” MCL 500.3106; MSA 24.13106.
Even where a person is occupying, entering into or alighting from a vehicle, it must still be shown that there is a causal relationship between the injury and the ownership, use, or maintenance of the vehicle. In the instant case while it may be true that but for her use of the car plaintiff would not have slipped, as previously noted this is not the proper test to apply. The trial court held there was no causal connection between her use of the automobile and the fact that she fell in the snow and I agree with that determination.
I would affirm.