Which of the following is NOT one of the three instances for due process for long arm statutes?

Due process in the context of long arm statutes pertains to the legal grounds on which a court can exercise jurisdiction over a non-resident defendant. The three traditional instances that establish such jurisdiction are typically based on whether the defendant has engaged in activities that have a substantial connection with the state.

Being a resident of the state is not an instance considered under long arm statutes. Instead, this principle applies to individuals who are already subject to the jurisdiction of the state simply by virtue of their residency. The purpose of long arm statutes is to extend a state's jurisdiction over individuals or entities that do not reside there but have engaged in specific activities that warrant the court's authority.

Engaging in a tort within the state, owning property in the state, and entering into a contract in the state are all activities that can create a sufficient connection, enabling the state to assert jurisdiction over a non-resident. In contrast, residency inherently implies the capacity for jurisdiction without needing the special provisions of a long arm statute, which focuses on non-residents.