This is because the original claimant, Pamela Jacobs, is a third party tort claimant, and § 500.2006 requires a showing of bad faith "[i]f the claimant is a third party tort claimant." There is a good faith argument to this effect under Auto-Owners Ins. Co. v. Ferwerda Enterprises, Inc., 797 N.W. 2d 168, 175 (Mich. Ct. App. 2010) judgment vacated in part,appeal denied in part sub nom. Auto-Owners Ins. Co. v. Ferwerda Enterprises, Inc., 784 N.W.2d 44 (Mich. 2010), and vacated sub nom. Auto-Owners Ins. Co. v. Ferwerda Enterprises, Inc., 789 N.W.2d 491 (Mich. 2010), which held that a showing of bad faith is required when the insured's claim is "specifically tied to the underlying third-party tort claim." After careful consideration of Ferwerda and its progeny, this Court holds Plaintiffs are entitled to automatic interest under § 500.2006 without a showing of bad faith for the same reasons explained by the Western District of Michigan and the U.S. Court of Appeals for the Sixth Circuit in Stryker Corp. v. XL Ins. Am. Inc., 726 F. Supp. 2d 754, 767 (W.D. Mich. 2010) and Stryker Corp. v. XL Ins. Am., 735 F.3d 349, 361 (6th Cir. 2012).

XL argues that all pre-judgment interest in this case is subject to the “reasonable dispute” rule, per Ferwerda I, because the Stryker I judgment stems ultimately from third-party tort claims against Stryker. Stryker, by contrast, argues that the Michigan Supreme Court vacated Ferwerda I via its subsequent decision in Ferwerda II. 784 N.W.2d 44 (Mich.2010) (Ferwerda II ). Thus, Stryker argues that we should not consider Ferwerda I at all, and instead reinstate the district court's original pre-judgment interest calculation.

XL argues that all pre-judgment interest in this case is subject to the “reasonable dispute” rule, per Ferwerda I, because the Stryker I judgment stems ultimately from third-party tort claims against Stryker. Stryker, by contrast, argues that the Michigan Supreme Court vacated Ferwerda I via its subsequent decision in Ferwerda II, 784 N.W.2d 44 (Mich.2010) (Ferwerda II ). Thus, Stryker argues that we should not consider Ferwerda I at all, and instead reinstate the district court's original pre-judgment interest calculation.

Our Supreme Court denied leave to appeal with regard to the penalty interest issue, but remanded with regard to the attorney fee issue. Auto–Owners Ins. Co. v. Ferwerda Enterprises, Inc., 784 N.W.2d 44 (Mich., 2010). Subsequently, the Court vacated this Court's ruling regarding attorney fees.

Our Supreme Court denied leave to appeal with regard to the penalty interest issue, but remanded with regard to the attorney fee issue. Auto–Owners Ins. Co. v. Ferwerda Enterprises, Inc., 784 N.W.2d 44 (Mich., 2010). Subsequently, the Court vacated this Court's ruling regarding attorney fees.

XL argues that all pre-judgment interest in this case is subject to the "reasonable dispute" rule, per Ferwerda I, because the Stryker I judgment stems ultimately from third-party tort claims against Stryker. Stryker, by contrast, argues that the Michigan Supreme Court vacated Ferwerda I via its subsequent decision in Ferwerda II, 784 NW2d 44 (Mich 2010) (Ferwerda II). Thus, Stryker argues that we should not consider Ferwerda I at all, and instead reinstate the district court's original pre-judgment interest calculation.