(dissenting). I dissent.
I would add the following facts to the majority’s statement of the facts in this case. Peterson was still seated when he reached for his shotgun, unzipped its case, and lifted the gun out with his hand on the trigger and on the hammer. His gun discharged as he swung it around to his right. Plaintiff was also seated when he was struck and neither of the van’s doors had been opened.
A motion for summary judgment under GCR 1963, 117.2(3) asserts that no genuine issue of material fact exists. Such a motion should not be granted when there is an issue of material fact, since the motion tests the factual support for plaintiffs claim. The trial court must consider the affidavits submitted, pleadings, depositions, admissions, and documentaiy evidence. The opposing party must show that a genuine issue of disputed fact exists. The test is whether the kind of record which might be developed, giving the benefit of doubt to the opposing party, would leave open an issue upon which reasonable minds might differ. This Court is liberal in finding a genuine issue of material fact. Linebaugh v Berdish, 144 Mich App 750, 754; 376 NW2d 400 (1985).
In this case, there is no dispute that plaintiff was the occupant of a parked motor vehicle and *367was preparing to unload it. MCL 500.3106; MSA 24.13106. The sole issue in this case is whether plaintiffs hand injury arose out of the use of a motor vehicle as a motor vehicle as required by MCL 500.3106(1); MSA 24.13106(1). I believe that there exists a genuine issue of material fact as to whether it did.
In Thornton v Allstate Ins Co, 425 Mich 643; 391 NW2d 320 (1986), our Supreme Court held that the plaintiff, a taxicab driver, who was shot by a "passenger” during a robbery, was not entitled to no-fault benefits under MCL 500.3105(1); MSA 24.13105(1). The Court held that there was no more than a "but for,” incidental, or fortuitous connection between the injuries inflicted upon the plaintiff and the "use of a motor vehicle as a motor vehicle(Emphasis in original.) Thornton, supra, p 646. The Court interpreted that phrase as follows:
In our view, this language shows that the Legislature was aware of the causation dispute and chose to provide coverage only where the causal connection between the injury and the use of a motor vehicle as a motor vehicle is more than incidental, fortuitous, or "but for.” The involvement of the car in the injury should be "directly related to its character as a motor vehicle.” Miller v Auto-Owners Ins Co, 411 Mich 633, 640-641; 309 NW2d 544 (1981). Therefore, the first consideration under MCL 500.3105(1); MSA 24.13105(1), must be the relationship between the injury and the vehicular use of a motor vehicle. Without a relation that is more than "but for,” incidental, or fortuitous, there can be no recovery of pip benefits. [Thornton, supra, pp 659-660.]
The Court further noted:
In this case, the inherent nature of the use of a *368motor vehicle did not cause Mr. Thornton’s [plaintiffs] injuries. Mr. Thornton was injured by a robber’s gunfire. While the injuries were perhaps "foreseeably identifiable” with the occupational or commercial use of a motor vehicle as a taxicab, the relation of the gunshot wound to the functional use of a motor vehicle as a motor vehicle was at most merely "but for,” incidental, and fortuitous. The mere foreseeability of an injury as an incident to a given use of a motor vehicle is not enough to provide no-fault coverage where the injury itself does not result from the use of the motor vehicle as a motor vehicle. [Thornton, supra, p 661. Emphasis in original.]
In Thornton, the Court distinguished its decision in Gajewski v Auto-Owners Ins Co, 414 Mich 968; 326 NW2d 825 (1982), reversing 112 Mich App 59; 314 NW2d 799 (1981). In Gajewski, the plaintiff, who was starting his vehicle, turned the ignition key, thereby detonating an explosive device which had been attached to the ignition mechanism by unknown persons. Plaintiff was severely injured and sued for no-fault benefits. The trial court granted plaintiff’s motion for summary judgment, finding plaintiff’s injuries occurred as a result of his operation of a motor vehicle. This Court reversed the trial court’s order, holding that such an injury was not foreseeably identifiable with the normal use or operation of a vehicle. This Court also noted that even though plaintiff had to turn the ignition key to detonate the explosive device, that it, and not the automobile, was the source of the injury.
Judge Cynar dissented, holding plaintiff’s act of turning the ignition key was identifiable with the normal manner of starting a vehicle. As such, the vehicle was more than the site of the injury; there was a direct causal relationship between the use of the motor vehicle and plaintiff’s injuries. The Su*369preme Court adopted Judge Cynar’s dissent when it reversed this Court’s decision. Id.
In Denning v Farm Bureau Ins Group, 130 Mich App 777; 344 NW2d 368 (1983), lv den 419 Mich 877 (1984), reh den 419 Mich 877 (1984), plaintiff sued to recover no-fault benefits on behalf of her husband. Plaintiff’s husband was transporting weed killer in his vehicle when he was overcome by its toxic fumes. He lost control of the vehicle and crashed. He died, not as a result of injuries suffered in the collision, but from a preexistent heart condition which was aggravated by his inhalation of the fumes. The trial court granted defendant’s motion for summary judgment, finding that plaintiff’s husband’s death was not foreseeably identifiable with the normal use and ownership of a motor vehicle and that his death could have occurred even if he had not been in an automobile. This Court reversed, holding that it was a question of fact whether plaintiff’s husband’s injuries could have occurred elsewhere, given the enclosed nature and movement inherent in an automobile.
In Shinabarger v Citizens Mutual Ins Co, 90 Mich App 307; 282 NW2d 301 (1979), lv den 407 Mich 895 (1979), the plaintiffs’ decedent was "shining” deer, using another person’s vehicle. Decedent, who was driving, spotted a deer, stopped the car, and attempted to shoot the animal. When reentering the automobile, he handed his shotgun to the person sitting next to him. At some point in this process or immediately thereafter, the shotgun accidentally discharged and fatally wounded decedent. The trial court granted summary judgment to plaintiffs, finding they were entitled to no-fault benefits. This Court reversed, holding:
Although the parties in the case at bar agreed that the motor vehicle was the site of the injury *370suffered by Shinabarger [decedent], there was no stipulation that the use of the vehicle was a cause of the accident Indeed, there is nothing in the record before us to indicate what caused the shotgun to discharge. Because the record does not establish a causal connection between use of the vehicle and the injury, the trial court erred in ñnding liability as a matter of law.
Plaintiffs argue on appeal that the injury to Gary Shinabarger occurred during the loading process, that loading is use of a motor vehicle as a motor vehicle, and that plaintiffs are therefore entitled to benefits. We agree that loading is use of a motor vehicle, especially so where there exists a separate loading clause in the policy description of coverage. [Citations omitted.] The requirement of a causal connection between the loading process and the injury, however, remains. [Citations omitted.]
* * *
In the case at bar, the record does not clearly reveal whether the accident occurred during the loading process and, if it did, whether there was a causal connection between the loading process and the injury. We therefore conclude that the trial court’s grant of summary judgment may not be upheld on the basis of the loading provision of § 3106. [Shinabarger, supra, pp 315-316. Emphasis supplied.]
I believe that from the above-discussed cases some rules may be drawn in determining whether a plaintiff’s injury is causally related to his vehicular use of an automobile. Thornton, supra. First, if a plaintiff’s use of a motor vehicle is only a "but for” cause of his injuries, he may not recover no-fault benefits because his injuries could have occurred even if he had not been using a motor vehicle. Id. However, even if the injury could have occurred elsewhere (i.e., a bomb explosion as in *371Gajewski, being overcome by toxic fumes as in Denning, or being shot as in Shinabarger), a plaintiff may recover if his use of the automobile is directly (causally) related to his injuries (i.e., turning the key while starting an automobile and detonating a bomb as in Gajewski or using a car to transport weed killer and having its fumes overcome you because of the enclosed nature and movement inherent in a motor vehicle as in Denning). See also MCL 500.3106(l)(b); MSA 24.13106(l)(b), which requires plaintiff’s injuries to be "a direct result of physical contact with . . . property being lifted onto or lowered from the vehicle in the loading or unloading process.” (Emphasis supplied.)
Under these rules, I believe that there is a genuine issue of material fact as to whether the unloading process in this case was causally related to plaintiff’s injury. Although I agree that this case differs from Shinabarger because defendant concedes plaintiff and Peterson were unloading the van, I also believe that this case is like Shinabarger because it is not clear what caused Peterson’s shotgun to discharge.
In this regard, I note that the circuit court found that the district court could have properly "inferred” that the van’s limited moving space and the location of its seats contributed to pláintiffs injury. The circuit court’s findings in this regard were speculative; again, as in Shinabarger, it was not clear what caused the shotgun to discharge.
Because plaintiff’s motion was brought on the ground that there existed no genuine issue of material fact, plaintiff’s motion was improperly granted. There did exist an issue of fact, namely, whether the unloading process, as opposed to Peterson’s and plaintiff’s own negligence, caused the *372firearm to discharge.1 Thornton, supra; Gajewski, supra; Denning, supra; Shinabarger, supra. If the unloading process did not cause the injury, the van was merely the site of the injury and plaintiff should not be able to recover. Id.
Peterson may have been intoxicated at the time he handled the weapon. Moreover, he may not have needed to unzip the gun case to unload the shotgun. Likewise, plaintiffs act of turning out the van’s lights may have contributed to the injury. I also note that Peterson apparently violated general hunting regulations by having a loaded shotgun in the van, MCL 312.10(l)(g)-(h); MSA 13.1339(l)(g)-(h).