Eighth Circuit Upholds Insurers' Residence Requirement for Homeowners Coverage

The Eighth Circuit Court ruled that homeowners insurance policyholders must actively reside in their insured properties to claim coverage, confirming insurers' strict interpretation of "residence premises" clauses. The case involved Liberty Mutual's denial of a claim for fire damage at a Minnesota home owned but no longer lived in by the policyholder. The court found the policy language unambiguous, requiring permanent or considerable residence to qualify for coverage. The policyholder, who had moved out of state but maintained ownership and occasional visits, did not meet the residency requirements during the policy period. The ruling also clarified that coverage for other household members depends on shared residence, applying a three-factor test in Minnesota: living under the same roof, close informal relationships, and substantial intended duration. The policyholder's sons were denied coverage as they lived separately. This decision supports insurers' ability to enforce coverage conditions based on clear policy language and is binding across the Eighth Circuit's jurisdiction, potentially influencing other regions. While the policyholder's personal property claim was settled, coverage for dwelling and other personal property claims was denied. This ruling underscores the importance of precise policy definitions in homeowners insurance and sets a precedent for interpreting residency requirements in claim disputes.