Future Plans to Move Do Not Defeat “Residency,” but “Household” Membership Turns on a Fact-Intensive Merger Inquiry (Georgia UM “Resident Relative” Coverage)

I. Introduction

Travelers Property Casualty Insurance Company v. Kamesha Davis (11th Cir. Aug. 18, 2026) addresses a recurring uninsured-motorist (“UM”) coverage question under Georgia law: when an adult child temporarily lives in property owned by a parent, does she qualify as a policy “resident relative”?

After Kamesha Davis was injured in a two-car accident, she pursued tort claims in Georgia state court and then sought UM benefits under an automobile policy issued by Travelers Property Casualty Insurance Company to her mother, Theresa Davis. Travelers filed a federal declaratory-judgment action contending Kamesha was not a covered “resident relative” because, although she was living at a house Theresa owned (257 Highway 308), she was not (a) a “resident” there and/or (b) a resident of Theresa’s “household.”

The district court granted summary judgment to Kamesha. On appeal, the Eleventh Circuit drew a sharp line between residency and household membership, affirming on the former and reversing on the latter.

II. Summary of the Opinion

  • Affirmed: Kamesha was a resident at Highway 308 as a matter of law. Her future, unconsummated plan to move to Jacksonville did not render her stay a “transient visitation.”
  • Reversed and remanded: Whether Kamesha was a resident of Theresa’s household presented genuine disputes of material fact. The record allowed competing inferences (i) about where Theresa’s household was (Theresa’s business property at 503 East Jefferson versus Highway 308) and (ii) about whether mother and daughter had merged into one household or maintained separate households “under different managements.”

III. Analysis

A. Precedents Cited

1. Jurisdictional framing (declaratory judgment amount in controversy)

Although not the merits, the panel addressed jurisdiction sua sponte through Federated Mut. Ins. Co. v. McKinnon Motors, LLC, emphasizing that in declaratory actions the amount in controversy is measured by “the monetary value of the object of the litigation from the plaintiff’s perspective.” The court found the jurisdictional minimum satisfied based on Kamesha’s pre-suit demand and the policy limit.

2. Summary judgment lens

The court applied de novo review under Signor v. Safeco Ins. Co. of Ill., and the “reasonable jury” material-dispute standard from Anderson v. Liberty Lobby, Inc., repeatedly using that framework to split the coverage inquiry into (i) a legal determination suitable for summary judgment (residency here) and (ii) a fact-bound determination not suitable on this record (household).

3. “Resident” under Georgia law (more than presence; not necessarily permanent)

The residency holding is built on a line of Georgia cases distinguishing “residence” from “domicile” and excluding purely transient visits:

  • Smiley v. Davenport: residence requires more than mere physical presence; a transient visit does not create residency; residence may reflect “intent to live in the place for the time being.”
  • Boston v. Allstate Ins. Co.: a person need not intend to live with the insured permanently to qualify as a “resident relative.”
  • Sanders v. Georgia Farm Bureau Mutual Insurance Co.: intent to live “exclusively” with a parent “even if only for the time being” can establish residence; conversely, leaving one residence for another can end residency at the former.
  • Travelers Property Casualty Insurance Co. v. Whitaker: illustrates “transient visitor” status where a child spent time at grandparents’ home but maintained an independent family arrangement elsewhere.

Using these authorities, the court treated Kamesha’s exclusive physical occupancy of Highway 308, her lack of any other housing, and her Georgia employment as decisive, while characterizing Jacksonville as a future possibility rather than a competing present residence.

4. “Household” under Georgia law (family living together; merger vs separate management)

For the second element—being a resident of the insured’s “household”—the court relied on Georgia cases that make “household” a holistic, fact-intensive inquiry:

  • Geiger v. Ga. Farm Bureau Mut. Ins. Co.: “household” means “a family living together.”
  • Travelers Ins. Co. v. Mixon: a person may have more than one residence.
  • Rainey v. State Farm Mut. Auto. Ins. Co.: courts look to “the aggregate details of the family’s living arrangements,” with critical emphasis on whether separate households are maintained “under different managements.”
  • S. Gen. Ins. Co. v. Foy: co-residence does not automatically create a single household; the court highlighted separate living areas and independent domestic routines as evidence of separate households.
  • Cotton States Mut. Ins. Co. v. McEachern: financial support/independence is an important factor in deciding whether a separate household exists under a different head or management.
  • Allred v. Progressive Cnty. Mut. Ins. Co.: highlights “interconnectedness” as a factor and cautions that household-intent evidence is “generally not susceptible to summary adjudication.”
  • Burdick v. GEICO: found a jury question where the adult child contributed to bills and shared some family life, yet also exhibited indicia of separate management (rent payments, distinct living space, and independent child-related responsibilities).

B. Legal Reasoning

1. The court formalized a two-step coverage inquiry

The opinion treats “resident relative” coverage as requiring two distinct showings: (1) residency at the relevant place and (2) residency in the insured’s household. The court’s disposition turns on keeping these elements separate—Kamesha could be a resident at Highway 308 yet still not be a resident of Theresa’s household.

2. Residency: “for the time being” defeats the “transient visitation” argument

The panel concluded no genuine dispute existed on residency because, even viewing evidence favorably to Travelers: Kamesha had moved in at the beginning of December, had ended her prior lease, had no other established home, and was living at Highway 308 exclusively at the time of the accident. Under Sanders v. Georgia Farm Bureau Mutual Insurance Co. and Smiley v. Davenport, her intent to live there “for the time being” was enough. The Jacksonville plan did not negate current residency because Georgia law does not require permanence.

3. Household: (i) where Theresa’s household was, and (ii) whether the households merged, were fact disputes

The court identified two independent reasons summary judgment was improper on “household”:

  1. Theresa’s household location was disputable. A reasonable jury could view 503 East Jefferson as Theresa’s household because she spent most nights there, had lived there “all [her] life,” and used it as her listed address. Or the jury could view Highway 308 as her household because she described going there as “go[ing] home,” spent substantial time there, and it functioned as the place where family support and daily life occurred.
  2. Even if Theresa’s household was at Highway 308, merger was disputable. Applying Rainey v. State Farm Mut. Auto. Ins. Co., Cotton States Mut. Ins. Co. v. McEachern, S. Gen. Ins. Co. v. Foy, and Burdick v. GEICO, the court stressed that cohabitation is not enough; the factfinder must determine whether the parties maintained separate households “under different managements.” Conflicting testimony on bill-sharing, phone expenses, grocery practices, and cooking—combined with missing facts about rent, division of space, and childcare expenses—left room for a jury to find either merger or separation.

The panel reinforced this conclusion with Allred v. Progressive Cnty. Mut. Ins. Co., emphasizing that household intent and living arrangements are typically ill-suited to summary judgment.

C. Impact

  • Insurers and insureds must litigate “resident relative” in two distinct phases. The opinion signals that courts may resolve “residency” as a matter of law where exclusivity and present intent are clear, while still sending “household” to the jury.
  • Future relocation plans are weakened as a residency defense. Where the claimant is living exclusively at the location at the time of loss, mere plans to move later may not defeat residency under Georgia law.
  • Household disputes will more often survive summary judgment. By leaning on Allred v. Progressive Cnty. Mut. Ins. Co. and analogizing to Burdick v. GEICO, the court encourages fact development on management, finances, space, and caregiving responsibilities.
  • Multi-property “household” questions remain open but practically jury-driven. The panel noted Georgia appellate courts have not said whether a person may maintain more than one household; rather than resolve it, the court treated the insured’s household location here as a fact issue. Future cases may press Georgia courts to clarify whether “household” is singular as a matter of law.

IV. Complex Concepts Simplified

Residence vs. domicile
Domicile is a permanent legal home. Residence can be temporary—living somewhere with intent to stay “for the time being.”
“Resident relative” (policy phrase)
Under this policy, it requires (1) a relative by blood/marriage/adoption and (2) that the relative is a resident of the insured’s household. The second part is not automatically satisfied just because the relative is living in a house the insured owns.
“Household”
A “household” is not just a building. It is the family unit living together under a common domestic management. People can live under one roof yet run separate “households” if finances, space, and daily life are managed independently.
“Separate households under different managements”
A practical test: Who pays which bills? Is there rent? Do they share meals and chores? Do they keep separate living areas? Are child expenses shared? These details determine whether there is one combined household or two separate ones.

V. Conclusion

Travelers Property Casualty Insurance Company v. Kamesha Davis clarifies that, under Georgia law, an adult child’s exclusive living arrangement “for the time being” can establish residency despite future plans to relocate. But it equally underscores that UM coverage for a “resident relative” turns on a separate—and usually fact-bound—question: whether the claimant was a resident of the insured’s household, assessed through the aggregate details of management, finances, and family interconnectedness. The result is a split disposition: residency resolved as a matter of law, household remanded for a factfinder.