Another young adult is basis for insurer dispute over domicile

Elizabeth Ulinski was struck and hurt by a car as she was crossing a highway.  25 years old, Elizabeth was another of those young people who have one foot in a parent's home and the other out.  In Elizabeth's case, she lived with friends and in cheap hotels and occasionally returned "home" to sleep on a roll-out couch in her old bedroom.  She kept some belongings there and used her mother's home as her mailing address, and on her ID card and voter registration.  The Auto Club, insurer of the car that hit her, maintained that everyone must have some domicile and that Elizabeth's home was her mother's.  Her mother's auto insurer, Frankenmuth, argued that Elizabeth was not domiciled in her household.

The trial court ruled that there were enough indicia to confirm that Elizabeth still made her domicile with her mother.  This ruling was based on the combination of facts showing no other residency and use of the mother's home as Elizabeth's retreat destination.  The Court of Appeals affirmed but chose not to decide whether, under Michigan law, every person must have some current domicile.