Jessica Hill v. State Farm Mutual Automobile Insurance Company

CourtKentucky Supreme Court
DecidedFebruary 20, 2025
Docket2024-SC-0054
StatusPublished

This text of Jessica Hill v. State Farm Mutual Automobile Insurance Company (Jessica Hill v. State Farm Mutual Automobile Insurance Company) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jessica Hill v. State Farm Mutual Automobile Insurance Company, (Ky. 2025).

Opinion

RENDERED: FEBRUARY 20, 2025 TO BE PUBLISHED

Supreme Court of Kentucky 2024-SC-0054-DG

JESSICA HILL APPELLANT

ON REVIEW FROM COURT OF APPEALS V. NO. 2023-CA-0203 JEFFERSON CIRCUIT COURT NO. 21-CI-005320

STATE FARM MUTUAL AUTOMOBILE APPELLEES INSURANCE COMPANY AND TYLER DELONJAY

OPINION OF THE COURT BY JUSTICE BISIG

REVERSING AND REMANDING

This case involves the interpretation of an insurance contract and

addresses a significant civic question-- does a minor child in the sole legal

custody of one parent qualify as a “resident relative” under the custodial

parent’s insurance policy if the child is staying elsewhere at the time of an

automobile accident. Seventeen-year-old Tyler Delonjay (“Tyler”) had a motor

vehicle accident in Jefferson County, Kentucky in August of 2020. Tyler struck

another vehicle and the Appellant, Jessica Hill (“Ms. Hill”), suffered injuries

and lost a pregnancy. Tyler, pursuant to a family court order, was in the sole

legal custody of his father, Jason Delonjay (“Jason”), for nine uninterrupted

years leading up to this collision. Further, there is no factual dispute that

Tyler was not physically staying with his father for several months when the accident occurred. Tyler’s mother was homeless and had not exercised custody

since 2011. Tyler lived with his father from 2011 to May of 2020. Tyler was

listed as a “dependent” on his father’s 2020 income taxes. Tyler’s driver’s

license, court documents and employment records listed his father’s address as

his own.

Despite these facts, because of disputes between father and son, Tyler

was staying with his father’s sister, Suzanne Small (Aunt Suzanne) and/or

various friends at the time the accident occurred. Tyler borrowed his Aunt

Suzanne’s vehicle and was driving with permission when he drove into Ms.

Hill’s car. Tyler’s father had a policy with State Farm that provided insurance

coverage if Tyler qualified as a “resident relative” defined as one who “resides

primarily” with the named insured. The policy did not define the terms

“resident,” “resides” or “primarily.” The issue is whether residency as used in

the insurance contract meant legal domicile or actual physical residence.

There is no dispute that father had legal authority over his minor son. Under

Kentucky law, an unemancipated minor child (even a seventeen-year-old)

cannot be without a home or guardian. There are mechanisms found in

various statutes for the state to intercede if a minor were found to be

abandoned, and the child would be referred to the Cabinet for Health and

Family Services. KRS 1 600.020; KRS 342.075; KRS 530.060.

Hill sued for damages resulting from the collision. In brief opinions, the

trial court granted summary judgment in favor of State Farm denying coverage

1 Kentucky Revised Statute.

2 and the Court of Appeals affirmed the decision. The Court of Appeals affirmed

the trial court finding the language of the policy clear and unambiguous. It

also cited to evidence that Tyler was not living at his father’s house when the

accident occurred. The Court of Appeals erroneously reasoned that Tyler not

physically living at his father’s residence the date of the accident was the

controlling factor in determining judgment in favor of State Farm. It construed

the policy language “primarily resides” as clear proof the policy intended

physical presence. Notably, in its analysis, the Court of Appeals did not

mention Tyler’s status as a minor or the family court custody orders.

In State Automobile Insurance Company v. Reynolds, 32 S.W.3d 508 (Ky.

2000) this Court discussed issues regarding a minor child’s legal status even

when not physically living at home. Per the logic in Reynolds, even though

Tyler was not residing with his father, some form of early emancipation did not

render him sui juris. Id. at 510 (citing Bensinger’s Coex’rs v. West, 255 S.W.2d

27, 28 (Ky. 1953)). In Perry v. Motorists Mutual Insurance Company, 860

S.W.2d 762 (Ky. 1993) this Court outlined guidance for determining residency.

The Perry court considered whether the individual was physically living in the

parents’ home as evidence, but not the sole controlling factor to establish

residency. Id. at 764. While the phrase “resident relative” was not at issue in

Perry, the analysis included consideration that there was no definition in the

Motorist Mutual policy for the term “resident” and that ambiguous terms must

be resolved in favor of coverage. Id. at 765.

3 For the 105 months of his life prior to the accident, Tyler lived with his

father. For 3 months immediately preceding to the accident, he lived at various

friends and his aunt’s. Accordingly, 97% of the time in the last 9 years, Tyler

lived with his father. This coupled with the family court sole-custody order, his

status as a minor, income taxes, job application, traffic ticket, and other

documentation result in a strong argument Tyler was “primarily” residing with

father. At minimum, the term “resident relative” is ambiguous as applied to

these facts. To wit, State Farm could have clearly defined “resident” in the

policy to mean “a person who physically resides in your household.” It did not.

When interpreting the residency language in an automobile insurance

policy, it is foreseeable for both insurer and insured that this type of issue may

unfold. It is a societal norm that families can find themselves embroiled in

difficult adolescent-parent relationship dynamics. While this specific legal

question is novel, other cases acknowledge the fluid and complicated nature of

residency in the timeframe surrounding emancipation. Old Reliable Ins. Co. v.

Brown, 558 S.W.2d 190, 191 (Ky. App. 1977). Importantly, the law does not

allow a minor child to be deemed as having “no residence” simply because they

leave a parental home for some period to avoid conflict.

Under the specific facts here, the Court finds the policy language was

unclear. When a term in a contract is ambiguous, courts construe the

language against the drafter of the policy. Majestic Oaks Homeowners Ass’n,

Inc. v. Majestic Oaks Farms, Inc., 530 S.W.3d 435, 441 (Ky. 2017). Ambiguous

insurance terms should be construed to favor insurance coverage rather than

4 restrict it. Perry, 860 S.W.2d at 765. Accordingly, we find the policy language

was ambiguous and therefore should be interpreted in favor of the insured.

The judgments of the trial court and Court of Appeals are hereby reversed, and

the case is remanded for the trial court to enter summary judgment on behalf

of Appellant, Jessica Hill.

FACTS AND PROCEDURAL BACKGROUND

This case arises out of a tragic August 5, 2020, automobile accident on

Bardstown Road in Jefferson County. Ms. Hill sustained serious injuries after

Tyler’s vehicle struck her from the opposite direction on the driver’s side door.

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Related

Kentucky Farm Bureau Mutual Insurance Co. v. McKinney
831 S.W.2d 164 (Kentucky Supreme Court, 1992)
Old Reliable Insurance Co. v. Brown
558 S.W.2d 190 (Court of Appeals of Kentucky, 1977)
Bensinger's Coex'rs v. West
255 S.W.2d 27 (Court of Appeals of Kentucky (pre-1976), 1953)
Perry v. Motorists Mutual Insurance Co.
860 S.W.2d 762 (Kentucky Supreme Court, 1993)
Moses v. Baker
798 F. Supp. 2d 863 (E.D. Kentucky, 2011)
Burr's Administrator v. Hatter
43 S.W.2d 26 (Court of Appeals of Kentucky (pre-1976), 1931)
State Automobile Insurance Co. v. Reynolds
32 S.W.3d 508 (Court of Appeals of Kentucky, 2000)
Caniff v. CSX Transportation, Inc.
438 S.W.3d 368 (Kentucky Supreme Court, 2014)

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Jessica Hill v. State Farm Mutual Automobile Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jessica-hill-v-state-farm-mutual-automobile-insurance-company-ky-2025.