Yes due to the auto insurance laws in Michigan there is relevance to the fact that you car was parked instead of you being on the street driving it at the time of the accident. In MI if your car is legally parked and hit then you can make a claim against the at fault party for the damages to your vehicle under their Property Protection Insurance (PPI), one of the required liability coverages a driver must have on their vehicle.

If instead you were driving your car and were rear-ended on the roadway you could not make a claim under PPI. In Michigan you would need to have collision coverage on your own vehicle to have your damages paid by insurance because the most you could get from the at-fault driver, or their insurance provider, is the mini-tort amount of $500. This amount is basically there to cover a person's collision coverage deductible.

Personal Protection will pay up to $1 million for damage your car does in Michigan to other people's property. Normally this means buildings, fences, poles, etc however this coverage will also pay for damage your car does to other people's properly parked vehicles. So you may need to prove that your car was "properly" parked to make your claim.

So as the insurance regulatory body for Michigan states in its auto insurance consumer guide, your no-fault insurance (basic PLPD policy) does not pay for repairs to your car if it is damaged in an accident. If your car is properly parked and hit by another car, the other driver's insurance will pay for your repairs. Except for this situation, the only kinds of auto insurance that pay for repairs to your car are collision and comprehensive coverage.