In Putkamer v. Transamerica Ins Corp of America, 454 Mich 626, 635-636; 563 NW2d 683 (1997), the Supreme Court of Michigan set forth a three-part test for recovery for injuries relating to a parked motor vehicle: Where a claimant suffers an injury in an event related to a parked motor vehicle, he must establish that the injury arose out of the ownership, operation, maintenance, or use of the parked vehicle by establishing that he falls into one of the three exceptions to the parking exclusion in subsection 3106(1). In doing so under 3106, he must demonstrate that: (1) his conduct fits one of the three exceptions of subsection 3106(1); (2) the injury arose out of the ownership, operation, maintenance, or use of the parked motor vehicle as a motor vehicle; (3) the injury had a causal relationship to the parked motor vehicle that is more than incidental, fortuitous, or but for.