Kevin Miller v. AXA Winterthur Ins. Co., 694 F.3d 675 (6th Cir. 2012). · Go Syfert
Kevin Miller v. AXA Winterthur Ins. Co., 694 F.3d 675 (6th Cir. 2012). Cases Citing This Book View Copy Cite
173 citation events (173 in the last 25 years) across 16 distinct courts.
Treatment trajectory · 2014 → 2026 · click a year to view as-of
2014 2020 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (rule) Alexander Ross v. Robinson, Hoover & Fudge, PLLC (2×)
6th Cir. · 2026 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012).
cited Cited as authority (rule) ArmyBassAnglers Enterprise LLC v. Jackson Outdoors, LLC, et al.
W.D. Ky. · 2026 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012)). 1 For reasons unclear to the Court, Defendants have filed two virtually identical motions to dismiss.
cited Cited as authority (rule) Mason Sales, LLC v. Talent Creation, LTD, and Mornington Corp., aka Mornington Corporation
M.D. Tenn. · 2026 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
cited Cited as authority (rule) Celesta Bryant, individually and as Administratrix of the Estate of Robert Tyler Bryant, et al. v. Michael Rauls et al.
W.D. Ky. · 2026 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012)).
cited Cited as authority (rule) Kevin Pratt v. Portfolio Recovery Associates; PRA Group, Inc.; and Vikram Atal
W.D. Tenn. · 2026 · confidence medium
Co., 694 F.3d 675, 680 (6th Cir. 2012)).
cited Cited as authority (rule) United States of America v. Don Kramer and Oakland County Treasurer
E.D. Mich. · 2026 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012)).
cited Cited as authority (rule) The Scotts Company LLC v. Acronym Media, Inc., et al.
S.D. Ohio · 2025 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012)).
cited Cited as authority (rule) Eric Mattson v. Oksana Kristen Singh and Iqbal Singh
E.D. Tenn. · 2025 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012).
cited Cited as authority (rule) Eric Mattson v. Oksana Kristen Singh and Iqbal Singh
S.D. Ala. · 2025 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012).
cited Cited as authority (rule) Robert Braun v. Bearman Industries, LLC
Ky. · 2025 · confidence medium
Co., 694 F.3d 675, 678-79 (6th Cir. 2012) (internal citation omitted).
cited Cited as authority (rule) Horner v. County Ohio
E.D. Tenn. · 2025 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012).
cited Cited as authority (rule) DV Injury Law, PLLC v. Tort Private Investigations LLC
E.D. Mich. · 2025 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
cited Cited as authority (rule) Coast to Coast Produce, LLC v. AMCO Produce Corporation
E.D. Mich. · 2025 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012) (citing Theunissen v. Matthews, 935 F.2d 1454, 1458 (6th Cir. 1991)).
cited Cited as authority (rule) Armstrong v. USA Automotive Partners, LLC
M.D. Tenn. · 2025 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012)).
discussed Cited as authority (rule) Shaik v. Finnegan
E.D. Mich. · 2025 · confidence medium
Co., 694 F.3d 675, 680 (6th Cir. 2012) (quoting S. Mach.
cited Cited as authority (rule) Strobl v. Croft
E.D. Tenn. · 2025 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012). 2 resident of Illinois who “invested money in ROI through the issuance of a promissory note in Scorpio,” another shell company.
cited Cited as authority (rule) Gronski v. Nice Systems, Inc
E.D. Mich. · 2025 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
cited Cited as authority (rule) Eastern CR Acquisition Inc. v. DeLuso
E.D. Mich. · 2024 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012).
cited Cited as authority (rule) Taste of Perfection, LLC v. Walker
M.D. Tenn. · 2024 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012).
cited Cited as authority (rule) Deters v. Meta Platforms, Inc.
E.D. Ky. · 2024 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012); Carrier Corp. v. Outokumpu Oyi, 673 F.3d 430, 449 (6th Cir. 2012).
cited Cited as authority (rule) BDD Group, LLC v. Crave Franchising, LLC
E.D. Mich. · 2024 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012) (citing Theunissen v. Matthews, 935 F.2d 1454, 1458 (6th Cir. 1991)).
cited Cited as authority (rule) Certified Flooring Installation, Inc. v. Young
E.D. Ky. · 2024 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012); Carrier Corp. v. Outokumpu Oyi, 673 F.3d 430, 449 (6th Cir. 2012).
cited Cited as authority (rule) Hutton v. U.S. Dept of Veterans Affairs
E.D. Tenn. · 2024 · confidence medium
Co., 694 F.3d 675, 680 (6th Cir. 2012)) (alteration in original).
cited Cited as authority (rule) Loft Holdings, LLC v. USC 28 Saginaw LLC
E.D. Mich. · 2024 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012).
discussed Cited as authority (rule) Arnold v. Poinsettia Homeowners Association, Inc.
E.D. Mich. · 2024 · confidence medium
Co., 694 F.3d 675, 680 (6th Cir. 2012) (quoting S. Mach.
cited Cited as authority (rule) Concord Music Group, Inc. v. Anthropic PBC
M.D. Tenn. · 2024 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012), but only specific personal jurisdiction is relevant here.
cited Cited as authority (rule) Gregory v. Ezricare, LLC
E.D. Ky. · 2024 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012); Carrier Corp. v. Outokumpu Oyi, 673 F.3d 430, 449 (6th Cir. 2012).
cited Cited as authority (rule) Shapira v. Rare Character Whiskey Co., LLC
W.D. Ky. · 2024 · confidence medium
Co., 694 F.3d 675, 680 (6th Cir. 2012).
discussed Cited as authority (rule) Kabisch v. RealPage, Inc. (2×) also: Cited "see"
M.D. Tenn. · 2024 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
cited Cited as authority (rule) Shannon v. Combe Incorporated
W.D. Ky. · 2024 · confidence medium
Co., 694 F.3d 675, 678-79 (6th Cir. 2012).
cited Cited as authority (rule) Krauss-Maffei Corporation v. Lepp
E.D. Ky. · 2023 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012); Carrier Corp. v. Outokumpu Oyi, 673 F.3d 430, 449 (6th Cir. 2012).
cited Cited as authority (rule) Davidson v. Nguyen-Sperry
S.D. Ohio · 2023 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
discussed Cited as authority (rule) Bradley v. Smith (2×)
E.D. Mich. · 2023 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
discussed Cited as authority (rule) PSI Marine, Inc. v. Seahorse Docking LLC
E.D. Mich. · 2023 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012), the Sixth Circuit held that ‘[f]or specific jurisdiction to exist in a diversity case, two factors must be satisfied: the forum state long-arm statute, and constitutional due process.’” (ECF No. 15, PageID.137.) In this trademark infringement case brought under the Lanham Act (in which jurisdiction is not based on diversity), the same factors must be satisfied, as set forth above.
cited Cited as authority (rule) Coeus Creative Group, LLC v. Gaffney
E.D. Mich. · 2023 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012) (internal and end citations omitted).
cited Cited as authority (rule) Michael Sullivan v. LG Chem Ltd.
6th Cir. · 2023 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012).
cited Cited as authority (rule) City of Pikeville v. Cebridge Acquisition, LLC
E.D. Ky. · 2023 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012); Carrier Corp. v. Outokumpu Oyi, 673 F.3d 430, 449 (6th Cir. 2012).
cited Cited as authority (rule) FORD MOTOR COMPANY v. KAWASAKI KISEN KAISHA LTD.
E.D. Mich. · 2023 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012).
cited Cited as authority (rule) Franklin Capital Funding, LLC v. Austin Business Finance, LLC
E.D. Mich. · 2023 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
cited Cited as authority (rule) Adams v. Crown Equipment Corporation
E.D. Ky. · 2023 · confidence medium
Co., 694 F.3d 675, 679 (6th Cir. 2012); Caesars Riverboat Casino, LLC v. Beach, 336 S.W.3d 51, 56-57 (Ky. 2011) (discussing K.R.S. § 454.210).
discussed Cited as authority (rule) Karri v. BMW (US) Holding Corp.
M.D. Tenn. · 2023 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012) (quoting Air Prods. & Controls, Inc. v. Safetech Int’1, Inc., 503 F.3d 544 , 549–50 (6th Cir. 2007)).
cited Cited as authority (rule) NetJets Aviation, Inc. v. Perlman
S.D. Ohio · 2022 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
cited Cited as authority (rule) Ncontracts, LLC v. Holmberg
E.D. Cal. · 2022 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012)).
cited Cited as authority (rule) Ncontracts, LLC v. Holmberg
M.D. Tenn. · 2022 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012)).
cited Cited as authority (rule) Straight v. LG Chem Ltd.
S.D. Ohio · 2022 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
cited Cited as authority (rule) IOU Central Inc. v. Division Avenue, LLC
W.D. Mich. · 2022 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012)).
cited Cited as authority (rule) Ensing v. Sephora USA, Inc.
N.D. Cal. · 2022 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
cited Cited as authority (rule) Ensing v. Sephora USA, Inc.
M.D. Tenn. · 2022 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012).
cited Cited as authority (rule) Ever-Seal, Inc. v. DuraSeal, Inc.
M.D. Tenn. · 2022 · confidence medium
Co., 694 F.3d 675, 678 (6th Cir. 2012)).
discussed Cited as authority (rule) Hamm v. Acadia Healthcare Co., Inc.
M.D. Tenn. · 2022 · confidence medium
Co., 694 F.3d 675, 678-79 (6th Cir. 2012) (citing Kerry Steel, Inc. v. Paragon Indus., Inc., 106 F.3d 147, 149 (6th Cir. 1997)).
Retrieving the full opinion text from the archive…
Kevin MILLER, Plaintiff-Appellant,
v.
AXA WINTERTHUR INSURANCE COMPANY, Defendant-Appellee
11-1751.
Court of Appeals for the Sixth Circuit.
Sep 13, 2012.
694 F.3d 675
ARGUED: Graham K. Crabtree, Fraser, Trebilcock, Davis & Dunlap, P.C., Lansing, Michigan, for Appellant. Clyde M. Metzger, Foley, Baron & Metzger, PLLC, Livonia, Michigan, for Appellee. ON BRIEF: Graham K. Crabtree, Anita G. Fox, Fraser, Trebilcock, Davis & Dunlap, P.C., Lansing, Michigan, for Appellant. Clyde M. Metzger, Judith A. Sherman, Foley, Baron & Metzger, PLLC, Livonia, Michigan, for Appellee.
Siler, Kethledge, Murphy.
Cited by 105 opinions  |  Published

OPINION

SILER, Circuit Judge.

Plaintiff Kevin Miller (“Miller”) seeks review of the Rule 12(b)(2) dismissal of his lawsuit for lack of personal jurisdiction over Defendant AXA Winterthur Insurance Company (“Winterthur”). The district court ruled that Miller had established a basis for personal jurisdiction under Michigan’s long-arm statute, but that the requirements of constitutional due process were not met. Miller disagrees, claiming that a document sent from Winterthur to Miller on October 3, 2005, demonstrates that Winterthur purposefully availed itself of Michigan law. Winterthur agrees with the district court’s ultimate disposition, but disagrees that it is subject to jurisdiction under the Michigan long-arm statute. For the following reasons, we affirm.

I.

In 2000 an “incident” occurred on the ice of a professional hockey game in Switzerland between Miller and Andrew McKim that resulted in McKim being injured. Swiss courts filed criminal charges against Miller for causing the injury. Allianz Insurance Company (“Allianz”) and ZLE Be[*678] triebs AG (“ZLE”), McKim’s insurance provider and hockey club, respectively, filed suit against Miller, and two separate civil judgments were entered against Miller. A direct claim was also made against Miller by McKim for his injuries. Miller left Switzerland sometime before these judgments were finalized and informed his hockey team and Winterthur (the insurance provider of his hockey club) that he no longer had the financial means to defend the litigation.

In 2005, a document (“Agreement”) was submitted to Miller in Michigan from Winterthur that notes Winterthur’s responsibility for the costs of criminal and civil judgments and proceedings pending with the Zurich District Court and previous attorneys’ fees:

It is hereby formally confirmed that Winterthur is responsible for the financial consequences of all judgments and costs arising out of
a) the criminal proceedings and
b) any civil proceedings relating to Mr. Andrew McKim’s direct claim against Mr. Kevin Miller based on the accident of 31st October 2000.
Winterthur is also responsible for the future costs of the civil proceedings pending with the Zurich District Court and brought by ZLE Betriebs AG and Allianz Suisse Insurance.
Winterthur shall cover previous attorneys’ fees in the amount of c. CHF 37,000 (Attorney Schober) and CHF 29,-267 (Attorney Dr. Peter).
This confirmation includes Winterthur’s responsibility for costs arising for Mr. Kevin Miller if he must pursue collection of amounts owed by Winterthur (such as, e.g., attorneys’ fees or travel costs).

Between April and December 2010, Allianz and ZLE submitted their demands for payment to Miller from the Swiss judgment. Miller, claiming reliance on the Agreement, presented these demands to Winterthur, which declined to pay the judgments in full. Miller brought this suit in Michigan circuit court seeking various contractual damages and enforcement of the terms of the Agreement. Winterthur removed the action to federal court based on diversity of citizenship, and filed a motion to dismiss under Rules 12(b)(2) and 12(b)(6) and, in the alternative, motions to dismiss for forum non conveniens and because the action was not ripe. The district court granted Winterthur’s motion to dismiss for lack of personal jurisdiction and declined to consider the other motions.

II.

We review personal jurisdiction determinations de novo. Kroger Co. v. Malease Foods Corp., 437 F.3d 506, 510 (6th Cir.2006); City of Monroe Emps. Ret. Sys. v. Bridgestone Corp., 399 F.3d 651, 664 (6th Cir.2005). “In diversity cases, federal courts apply the law of the forum state to determine whether personal jurisdiction exists.” Nationwide Mut. Ins. Co. v. Tryg Int’l. Ins. Co., 91 F.3d 790, 793 (6th Cir.1996) (citation omitted). In response to a motion to dismiss, the plaintiff may not stand on his pleadings, but must show the specific facts demonstrating that the court has jurisdiction. Theunissen v. Matthews, 935 F.2d 1454, 1458 (6th Cir. 1991). In order to defeat the motion to dismiss the plaintiffs affidavit(s) must make only a prima facie showing. Id. The pleadings and affidavits are viewed in the light most favorable to the plaintiff. Kerry Steel, Inc. v. Paragon Indus., Inc., 106 F.3d 147, 153 (6th Cir.1997).

Personal jurisdiction may be found either generally or specifically. Air Prods. & Controls, Inc. v. Safetech Int’l, Inc., 503 F.3d 544, 549-50 (6th Cir.2007). General jurisdiction depends on continuous[*679] and systematic contact with the forum state, so that the courts may exercise jurisdiction over any claims a plaintiff may bring against the defendant. Kerry Steel, 106 F.3d at 149. Specific jurisdiction, on the other hand, grants jurisdiction only to the extent that a claim arises out of or relates to a defendant’s contacts in the forum state. Id.

Miller has alleged only specific jurisdiction in his brief, and since Miller has not shown that Winterthur has carried on systematic conduct, has consented to jurisdiction, or is incorporated under the law of Michigan, courts may not exercise general personal jurisdiction over Winterthur in Michigan. “[CJontact with and activity directed at a sovereign may justify specific jurisdiction ‘in a suit arising out of or related to the defendant’s contacts with the forum.’ ” J. McIntyre Mach., Ltd. v. Nicastro, — U.S. -, 131 S.Ct. 2780, 2788, 180 L.Ed.2d 765 (2011) (quoting Helicópteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 414 n. 8, 104 S.Ct. 1868, 80 L.Ed.2d 404 (1984)). For specific jurisdiction to exist in a diversity case, two factors must be satisfied: the forum state long-arm statute, and constitutional due process. [1] Air Prods., 503 F.3d at 550; see Int’l Shoe Co. v. State of Wash., Office of Unemployment Comp. & Placement, 326 U.S. 310, 319-20, 66 S.Ct. 154, 90 L.Ed. 95 (1945). It is not necessary to decide if due process has been satisfied if the requirements of the long-arm statute are not met. Green v. Wilson, 455 Mich. 342, 565 N.W.2d 813, 816-17 (1997).

A. Michigan’s Long-Arm Statute

The district court found that Michigan’s long-arm statute was satisfied because it allows personal jurisdiction over a corporation that is involved in “the transaction of any business in the state.” [2] Mich. Comp. Laws § 600.715(1); see Sifers v. Horen, 385 Mich. 195, 188 N.W.2d 623, 624 n. 2 (1971) (explaining that “[t]he word ‘any’ means just what it says. It includes ‘each’ and ‘every.’”). Furthermore, the “slightest act of business in Michigan” is a sufficient business transaction for purposes of the statute. Neogen Corp. v. Neo Gen Screening, Inc., 282 F.3d 883, 888 (6th Cir.2002); see Oberlies v. Searchmont Resort, Inc., 246 Mich.App. 424, 633 N.W.2d 408, 413 (2001).

Although no financial transaction occurred, we assume, without deciding, that the district court was correct in holding that the letter sent from Winterthur to Miller was a nominal business transaction that satisfied the Michigan long-arm statute.

B. Constitutional Due Process

Assuming arguendo that the Agreement satisfied Michigan’s long-arm statute as held by the district court, the subsequent due process requirement of personal jurisdiction has not been met. For specific jurisdiction to exist, the defendant must have certain minimum contacts with the forum state. Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475, 105 S.Ct. 2174,[*680] 85 L.Ed.2d 528 (1985); see Int’l Shoe, 326 U.S. at 316, 66 S.Ct. 154. We have articulated a three-part test for recognizing due process in personal jurisdiction cases:

First, the defendant must purposefully avail himself of the privilege of acting in the forum state or causing a consequence in the forum state. Second, the cause of action must arise from the defendant’s activities there. Finally, the acts of the defendant or consequences caused by the defendant must have a substantial enough connection with the forum state to make the exercise of jurisdiction over the defendant reasonable.

S. Mach. Co. v. Mohasco Indus., Inc., 401 F.2d 374, 381 (6th Cir.1968). If any of the three requirements is not met, personal jurisdiction may not be invoked. LAR, Inc. v. Deer Creek Enters., 885 F.2d 1293, 1303 (6th Cir.1989).

1. Purposefully Avail

Any contacts Winterthur may have had with Michigan were so attenuated that they could not demonstrate purposeful availment of the forum state. Our decision is consistent with case law. In Nationwide Mut. Ins. Co., 91 F.3d at 795-96, we found that due process was not satisfied even though Tryg sent a letter to Nationwide’s corporate headquarters in Ohio, entered into an agreement with Nationwide, sent an agent to Ohio, solicited business from Nationwide in Ohio, and realized profits from its contacts with Ohio. Winterthur sent a letter to Miller in Michigan and reached an agreement with Miller while both parties were in Switzerland, but no more.

In LAK, we held that due process was not satisfied when a Michigan corporation sued an Indiana partnership over a property contract. See LAK 885 F.2d at 1303. The plaintiffs attorneys exchanged repeated phone calls and drafts of the agreement with the defendant in Indiana. The mere fact that the defendant in Indiana utilized the mail to send documents to Michigan did not constitute purposeful availment, and the contract between the parties did not qualify as an ongoing business relationship. Id. at 1301. Similarly, the Agreement was communicated between Winterthur’s attorneys in Switzerland and Miller’s attorneys in Michigan. Even though this communication was intentionally directed to Michigan, it fails to demonstrate that Winterthur purposefully availed itself of Michigan law.

In Calphalon Corp. v. Rowlette, 228 F.3d 718, 722-24 (6th Cir.2000), we held that a contract was not sufficient to satisfy due process when none of the terms of the contract was to be performed in the forum state; the fact that a contract existed between the parties but in no way implicated action in the forum state was merely fortuitous. See Burger King, 471 U.S. at 478, 105 S.Ct. 2174 (“If the question is whether an individual’s contract with an out-of-state party alone can automatically establish sufficient minimum contacts in the other party’s home forum, we believe the answer clearly is that it cannot.”). Here, the district court has already determined that the Agreement exchanged between the parties created no contractual obligations, and even if it did, they were not to be performed in Michigan. The Agreement simply stated several financial obligations from Miller’s preexisting insurance policy in Switzerland concerning litigation in Switzerland. These obligations existed regardless of where Miller resided, and thus the fact that he was in Michigan when he received the document was merely coincidental.

A Arising From

The district court found that Miller has established that his cause of action[*681] does arise from Winterthur’s contacts with Michigan. Although the contact in question, the Agreement, was not sufficient to purposefully avail Winterthur of Michigan law, it is the direct source of Miller’s cause of action. Therefore, Miller has demonstrated that his cause of action is “related to” or “connected with” Winterthur’s contact with the forum state.

3. Reasonableness

The district court found that Miller has not demonstrated that it is reasonable to exercise personal jurisdiction over Winterthur. The burden on Winterthur would be heavy, as it has no presence in Michigan, and it would be forced to litigate a contract case created under Swiss law in the United States court system. All of the events underlying the Agreement, insurance policy, and hockey injury occurred in Switzerland, and all of the evidence and witnesses are there as well. Moreover, the insurance policy that exists between the parties includes a Swiss forum selection clause and a Swiss choice of law provision. Accordingly, if we granted jurisdiction here it is very possible that the case would ultimately be transferred to Switzerland under these contractual terms. Finally, all of the relevant trial materials would have to be translated from German to English. It would therefore be more efficient to litigate the case in Switzerland.

The district court points out that Miller would be burdened by traveling to Switzerland, but this is not the same as saying that he could not find relief there. Moreover, it appears from the Agreement that travel is a covered cost of his insurance policy. The district court also notes that Michigan has only a token interest in the disposition of this lawsuit. [3] The weight of these factors demonstrates that it is not reasonable for Winterthur to defend this case in Michigan.

III.

For the foregoing reasons, we agree with the district court that Winterthur is not subject to specific personal jurisdiction in Michigan.

AFFIRMED.

1

. Generally, long-arm statutes that confer jurisdiction to the extent of due process only require a one-step consideration of due process. Green v. Wilson, 455 Mich. 342, 565 N.W.2d 813, 816 (1997). Some Michigan courts have interpreted Michigan's long-arm statute to be coextensive with due process in certain respects, but we still must consider both factors since the language of the statute enumerates specific instances where jurisdiction may be exercised. Id.

2

. Later in the opinion, however, the district court said that the long-arm statute was only "likely” satisfied. It appears from the opinion that the district court did, in fact, find personal jurisdiction under Michigan Compiled Laws § 600.715(1).

3

. However, some case law suggests that states do have a high interest in protecting their citizens’ rights under insurance policies. See Hanson v. Denckla, 357 U.S. 235, 252, 78 S.Ct. 1228, 2 L.Ed.2d 1283 (1958) (affirming that a state has an increased interest in providing redress against out-of-state defendants in activities “that the State treats as exceptional and subjects to special regulation,” such as insurance.); McGee v. Int’l Life Ins. Co., 355 U.S. 220, 223, 78 S.Ct. 199, 2 L.Ed.2d 223 (1957) (a state “has a manifest interest in providing effective means of redress for its residents when their insurers refuse to pay claims”).