The State of Ohio has a residency requirement stating that no license will be issued or renewed to an applicant who is not a resident of Ohio. After Michigan residents incorporated in Ohio but were unable to obtain Ohio licensure either individually or as a corporation, Michigan amended its licensure statute in 1978 to deny licenses to applicants who reside in a state that would deny a license solely because of residency. Sill-Indiana is an adjusting firm that operates and employs adjustors residing in Indiana, which has reciprocity with Michigan. Sill-Indiana, however, is an affiliate of Sill-Ohio, an adjusting firm in Ohio, and is entirely owned, incorporated, directed, and controlled by Robert Sill, an Ohio resident. In 1992, Sill-Indiana adjustors were granted licenses to practice in Michigan but the licenses were revoked by the Insurance Commissioner in 1996 after a hearing in which the National Association of Public Insurance Adjustors argued that Sill-Ohio was avoiding the legislative intent of the Michigan licensure law simply by incorporating a Sill corporation in a neighboring state without a residency requirement. A stay of revocation was filed while the decision was on appeal, and in 1997 the circuit court reversed the Insurance Commissioner's decision. In August 1999, the Michigan Court of Appeals reversed the circuit court and found that the Insurance Commissioner's interpretation of the Michigan licensure statute was "sufficiently reasonable" (O'Connor, et. al. v Consumer and Industry Services, et. al., 236 Mich App 665). The Insurance Commissioner had found that Robert Sill, the Ohio resident and owner of Sill-Indiana, was not entitled to achieve "the authority of a license through the Indiana corporation that he owns". The Insurance Commissioner reasoned that if the Sill-Indiana adjustors were permitted to have licenses to work in Michigan, Sill-Ohio would be able to adjust claims in Michigan through its employees, even though Sill-Ohio itself was prohibited from doing so.