Lipscomb v. GEICO

43 Va. Cir. 326, 1997 Va. Cir. LEXIS 382
CourtRichmond County Circuit Court
DecidedSeptember 10, 1997
DocketCase No. HH-374-3
StatusPublished

This text of 43 Va. Cir. 326 (Lipscomb v. GEICO) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lipscomb v. GEICO, 43 Va. Cir. 326, 1997 Va. Cir. LEXIS 382 (Va. Super. Ct. 1997).

Opinion

By Judge T. J. Markow

This letter concerns fee Petition for Declaratory Judgment filed to determine fee rights and obligations of fee parties to this controversy. The court has heard fee evidence and has considered fee various arguments made by fee parties and rendas fee following decision.

On Friday, January 26, 1996, fee plaintiff, Brenda A. Lipscomb, was involved in a head-on automobile collision in fee City of Blackstone wife a vehicle driven by fee defendant, William H. Odom, Jr., and owned by fee defendant, Earl M. Trivette. Amanda B. Trivette, daughter of Earl Trivette, was a passenger in fee automobile driven by Odom.

This automobile, although owned by Earl Trivette, was for fee general use of Amanda Trivette and insured by fee defendant GEICO Insurance Company. Insurance coverage to fee family members of fee defendant Odom, Mr. and Mrs. John T. Knapp (Odom’s grandparents) and Pamela Knapp [327]*327(Odom’s mother), was provided by Allstate Insurance Company. The plaintiffs uninsured motorist coverage was provided by Integon/New South Insurance Company.

Odom and Amanda Trivette had been dating for over one year prior to toe date of toe accident. Amanda resided with her parents in Blackstone; Odom resided with his grandparents in Crewe.

At toe time of toe accident, Odom’s mother, Pamela Knapp, was temporarily residing in a travel trailer which was located on toe same property as toe home of her parents, Mr. and Mrs. John Knapp. Odom had resided with his grandparents since approximately 1975; they were his legal guardians. Pamela Knapp moved onto toe property in September 1995 in order to "get her feet on toe ground” and pursue a college education. Site remained in toe trailer until approximately November 1996. The trailer was located between 100 and 150 yards from toe main Knapp house; it did not have running water, sewage service, a telephone, or a separate post office box. Electricity was provided via a hook-up to toe Knapp’s house. Pamela Knapp and her young son, C.J., used toe toilet and shower facilities in toe house. They also took most of their meals in toe house. Pamela Knapp only intended a temporary stay in Crewe until her finances were in order. When possible, she paid John Knapp rent of $100 per month. Except for sanitary facilities and family meals, toe two residences were maintained as separate entities. Pamela Knapp also owned a pickup track, which was insured by Allstate.

Depending on toe week, Odom spent between two and five nights per week at toe Trivette home. He shared Amanda’s room and was occasionally chaperoned by her mother, Sadie Trivette. Both teens had automobiles at their disposal. Odom drove a Nissan pickup track owned by his grandparents, Mr. and Mrs. John Knapp, and insured by Allstate. Amanda Trivette drove a Pontiac Grand Am automobile owned by her father, Earl Trivette, and insured by GEICO.

Amanda Trivette was repeatedly told by her parents that no one else was permitted to drive toe car. This prohibition was occasionally (but not always) reiterated after Earl or Sadie Trivette observed Odom driving toe Pontiac. The Trivettes did not specifically invoke toe prohibition with regard to Odom, nor did they ever speak directly to Odom and forbid his use of toe Pontiac. The Trivettes were aware of repeated instances of use, and Odom testified that he never made an effort to “hide” his use of toe car. In fact, Odom was frequently seen by toe Trivettes parking toe Pontiac in front of toe family’s home or driving their daughter to a nearby convenience store. Although Odom admits that he overheard toe Trivettes’ admonishments to their daughter and assumed [328]*328that they applied to his use of Amanda’s car, he drove the Pontiac whenever she asked him to do so.

Once again, neither Mr. nor Mrs. Trivette ever told Odom that he was barred from driving this automobile. Due to discomfort with her eyeglasses, Amanda Trivette expressly requested that Odom drive at night, during rainstorms, when it was foggy, or when applying cosmetics on the way to school. On the Friday morning in question, Amanda requested Odom’s assistant» in order that she be able to study for a test while the two teens drove to their high school.

The parties are seeking a declaratory judgment in order to determine whether the defendant Odom is entitled to insurance coverage, and.if so, which party is requited to satisfy this claim.

There are three issues at stake here. First, whether Odom is Pamela Knapp’s resident relative, such that her insurance policy will cover Odom’s liability arising from this accident Second, whether Odom is a resident relative of Mr. and Mrs. John Knapp, such that their insurance policy will cover Odom’s liability arising from this accident Resolution of these first two issues turns on the definition of "resident relative" and the "reasonableness” of Odom’s belief that he had permission to use the Pontiac automobile. Finally, the third issue is whether Odom was engaged in the "permissive use” of the car owned by Earl Trivette at tire time of this incident so as to enjoy coverage under the GEICO policy issued on that automobile.

The relevant statute is Va. Code § 38.2-2204(A) (the "omnibus clause”). There ate two components of this statute, the first of which covers automobiles "owned” by the insured. Coverage for "owned” automobiles includes the owner himself and extends to persons using this motor vehicle with the express or implied consent of the owner/named insured. Here, the "owned” vehicle is die Pontiac; the "owner” and named insured on the GEICO policy is Earl Trivette. The issue is whether Odom was engaged in "permissive use” of Earl Trivette’s Pontiac.

The second component of this statute addresses coverage of "non-owned” automobiles (i.e., not owned by the insured party) that are used by the insured party himself or his resident relatives. Coverage for the use of “non-owned* automobiles extends to motor vehicles used by the insured party or his relatives with the consent of tire third-party owner or custodian. Here, the “insured parties” are Pamela Knapp and John Knapp (each has a separate Allstate policy); the "non-owned* vehicle is the Pontiac; die third-party "owner” is Earl Trivette, and the "custodian” is Amanda Trivette.

For purposes of the omnibus clause of § 38.2-2204(A), a custodian’s consent is only sufficient when seeking to determine whether permission was [329]*329granted for use of a "non-owned” vehicle. Users of a vehicle "owned” by the insured must obtain fee express or implied permission of fee owner, fee custodian’s consent will not suffice in this context.

The "owned" vehicle component of fee omnibus clause is relevant to deciding fee first and second issues (fee "resident relative” question). It is undisputed by fee parties feat Odom is a resident relative of Mr. and Mrs. John Knapp, i.e., fee three individuals are residents of fee same household. A household is generally defined as “a collection of persons living together as a single group wife one head under one roof, a unit of permanent and domestic character.” Furrow v. State Farm Mut. Auto. Ins. Co., 237 Va. 77, 80 (1989) (citations omitted). An individual’s subjective intent is also determinative of "resident" status. Allstate Ins. Co. v. Patterson, 231 Va. 358, 363 (1986).

In this case, Mr. and Mrs. Knapp obtained legal custody of Odom at an early age, raising him as their own child and providing a room in fee family house for his use.

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Related

Furrow v. State Farm Mutual Automobile Insurance
375 S.E.2d 738 (Supreme Court of Virginia, 1989)
Allstate Insurance v. Patterson
344 S.E.2d 890 (Supreme Court of Virginia, 1986)
Gordon v. Liberty Mutual Insurance
675 F. Supp. 321 (E.D. Virginia, 1987)
Hinton v. Indemnity Insurance Co. of North America
8 S.E.2d 279 (Supreme Court of Virginia, 1940)

Cite This Page — Counsel Stack

Bluebook (online)
43 Va. Cir. 326, 1997 Va. Cir. LEXIS 382, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lipscomb-v-geico-vaccrichmondcty-1997.