(dissenting).
I respectfully dissent. It is challenging, to say the least, to review our jurisprudence and determine where to properly draw the line on a maintenance and use of a motor vehicle issue involving the Minnesota No-Fault Automobile Insurance Act, Minn.Stat. § 65B.41-65B.71 (2004). Nonetheless, I conclude after a thorough review of the record that respondent’s injuries are not reasonably attributable to the maintenance or use of a motor vehicle.
Minnesota’s No-Fault Act provides that “every person suffering loss' from injury arising out of maintenance or use - of a motor vehicle * * * has a right to basic economic loss benefits.” Minn.Stat. § 65B.46, subd. 1 (2004) (emphasis added). “Maintenance or use of a motor vehicle” is defined as “maintenance or use of a motor vehicle as a Vehicle, including, incident to its maintenance or use as a vehicle, occupying, entering into, and alighting from it.” Minn.Stat. § 65B.43, subd. 3 (2004). The required causal connection between maintenance or use of the vehicle and injury is something more than that the vehicle was the mere situs of the injury, but is something less than proximate cause in the tort sense. Continental W. Ins. Co. v. Klug, 415 N.W.2d 876, 878 (Minn.1987).
While it is difficult to draw the line between covered injuries and injuries too tenuously connected to the motor vehicle to warrant the protection of the No-Fault Act, defining maintenance and use too broadly undermines the policies of the Act. In Marklund, we noted the importance of limiting the definition of injuries arising out of maintenance and use of a motor vehicle to those injuries that, according to the policies of the Act, should be allocated to the costs of motoring. Marklund v. Farm Bureau Mut. Ins. Co., 400 N.W.2d 337, 339 (Minn.1987). We cited the Commissioner’s Comments to the Uniform Motor Vehicle Accident Reparations Act, on which Minnesota’s No-Fault Act is modeled, and stated:
In some cases * * * it is arguable that courts have included accidents too far removed from the general activity of motoring and that a narrower construction of the term would be more consistent with the policy of this Act. Other than specifying that injury arise out of maintenance or use “as a vehicle,” it has not been possible to define the general concept more specifically, so borderline cases are left to the courts, as they have been under current automobile policies.
Marklund, 400 N.W.2d at 339 n. 4 (citing Commissioner’s Comments, Unif. Motor Vehicle Accident Reparations Act § 1, 14 U.L.A. 56 (1980)). Thus, some cases are simply too far removed from motoring to be included in the scope of the no-fault system. The No-Fault Act seeks to ameliorate the distress of automobile accident victims. See Minn.Stat. § 65B.42 (2004); *748Galle v. Excalibur Ins. Co., 317 N.W.2d 368 (Minn.1982).
We have said that causation may be framed in terms of whether the vehicle is “an accessory” to the injuries sustained. Holm v. Mut. Serv. Cas. Ins. Co., 261 N.W.2d 598, 603 (Minn.1977). Stated in terms of exclusion, a vehicle that is not an accessory to the injury is a “mere situs” of the injury. Nat’l. Family Ins. Co. v. Boyer, 269 N.W.2d 10, 14-15 (Minn.1978).
Here, we cannot say that Dougherty’s vehicle is “an accessory” to her injuries. Dougherty lodged her vehicle in a snow bank approximately 300 feet from her apartment building. Her injuries may be attributable to many different causes, including falling asleep outside with a wind chill of 45 degrees below zero, apparent inability to negotiate icy walking conditions or perhaps even her intoxication, but her use of the vehicle was entirely incidental to the injuries sustained.
The heart of the majority opinion is found in the conclusion that the causal connection between Dougherty’s injuries and the use of her vehicle “is established because it is a ‘natural and reasonable incident or consequence’ of the use of a vehicle in Minnesota in the winter because a vehicle may become lodged in a snowdrift and the driver may attempt to seek safety, as Dougherty did here.”
But there is no precedent remotely supporting Dougherty’s claim for benefits under the Minnesota No-Fault Act and what little relevant law exists tends to support the conclusion that there is no causal link between Dougherty’s injuries and her use of the vehicle. For example, in Marklund, as the majority notes, we concluded that the slip and fall injury was a result of a premises hazard and there was no causal connection to the maintenance of a motor vehicle. Marklund, 400 N.W.2d at 341. Marklund was walking to a cashier to pay for gasoline he had pumped when his slip and fall accident occurred. Id. at 340. Here, Dougherty’s injuries also resulted from a premises hazard — icy walking conditions — encountered as she walked from her disabled vehicle to her apartment building.
In Holm, a police officer pursued a plaintiff in a municipal police car, left the vehicle and committed a battery on the plaintiff. 261 N.W.2d at 599, 602. Noting that the police officer “used the police car only as a means of transportation to the scene of the arrest and battery,” and that the officer was “physically separated from the vehicle” at the time of injury, we held that the vehicle was not an “accessory” to the battery and thus the causal connection was broken. Id. at 603-04.1 Indeed, in the present dispute, Dougherty not only left the vehicle, she locked the doors of the vehicle, arguably abandoning it, a circumstance not present in Holm.
I acknowledge that Holm involved an intentional battery not present here and thus the comparison is far from exact; Holm and Dougherty’s circumstances, however, share this in common — the injury at issue was not attributable to the use of a motor vehicle. While it is certainly possible to envision fact patterns that involve stranded motor vehicles in dangerous circumstances, and a resulting conclusion that notwithstanding separation from the vehicle benefits under the Minnesota No-Fault Act are awardable, Dougherty’s injuries were not caused by anything remotely *749related to the normal incidents of motoring and extending the protection of the No-Fault Act to these circumstances eviscerates the policies of the Act.
I conclude that Dougherty's injuries are not the “natural and reasonable incident or consequence” of her use of her motor vehicle and I would reverse the court of appeals.
. The question of maintenance or use of the police vehicle in Holm involved the city's liability insurance policy and not the Minnesota No-Fault Act. We have stated that, as opposed to private insurance contracts, a narrower definition of maintenance and use under the No-Fault Act serves the policies of the Act. See Marklund, 400 N.W.2d at 339.