In Grange Mutual Casualty Company v. Estate of Stephen Stetz, 2018 Ind. App. LEXIS 72 (Ind. Ct. App. 2018), the court found—under Ohio law—that Stephen Stetz (who tragically died after being struck by an uninsured motorist) qualified for benefits under his parents’ auto policy as a “family member” because his “principal residence” remained at his parent’s house in Ohio even though he had been living and working in Chicago for over a year.
The Principal Issue
The parents’ auto policy provided uninsured motorists benefits to the named insured (Stephen’s parents) and any “family member.” “Family member” was defined as: “[A] person related to you by blood, marriage or adoption and whose principal residence is at the location shown in the Declarations.” Thus, to qualify for benefits, Stephen’s “principal residence” had to be at his parents’ house in Uniontown, Ohio (which was the location shown on the declarations page). At the time of his death, Stephen had been living and working in Chicago for over a year. Stephen’s estate filed suit and moved for summary judgment, seeking uninsured motorists coverage under the parents’ Grange Mutual auto policy.
The Court’s Analysis
The trial court granted summary judgment in favor of the estate, finding that Stephen’s principal residence was at his parents’ house. The trial court noted that, while it was clear Stephen was “living” in Chicago at the time of his death, the “insurance policy in question does not reference where one is ‘living’, but rather the insurance policy employs the words ‘principal residence’.” The terms “principal residence” were not defined in the policy, and the court looked to other sources—dictionaries and case law—to construe these terms. Finding these terms ambiguous, the court construed them broadly in favor of coverage.
In finding that Stephen’s “principal residence” was his parents’ house in Uniontown, Ohio, the court considered that Stephen: drove a parent-owned car; had an Ohio driver’s license with the Uniontown address; had a key to the Uniontown house; was registered to vote (and did vote) in Ohio; would visit “fairly often,” and he did not have to bring a suitcase with him when he visited because “he had everything he needed;” kept his local Key Bank account in Uniontown; received financial support from his parents (including co-signing a lease and paying security deposits and last month’s rent); continued to receive care from his longtime family doctor, dentist, and eye doctor in Ohio; and told his mother and long-time friend that he intended to return to Uniontown after his work assignment in Chicago. Even though Stephen had been living and working in Chicago for over year, the court opined that Stephen’s situation “much more resembled a graduate student away at school than he did someone who has fully moved and relocated to a new city leaving his childhood home behind.” The Court of Appeals agreed with the trial court, found the terms “principal residence” ambiguous, and held that the estate was entitled to uninsured motorists benefits because Stephen’s “principal residence” was at his parents’ house in Ohio.
Three Principal Takeaways
- One’s “principal residence” is not simply where one lives and works.
- Ohio courts, just like Indiana courts, consult various sources (such as dictionaries and other case law) when construing undefined insurance policy terms.
- Insurance coverage can be found in unexpected places. See, e.g., Searching for Insurance Coverage for Auto Accidents? Check the Employer’s Auto Policy. Every potential source of recovery should be investigated.