Car Insurance Residence Exclusions In Colorado

In the context of automobile insurance exclusions, residence is determined on a case-by-case basis using factors such as intent and relative permanence. Midwest Mutual Insurance Co. v. Titus, supra. In general, residence denotes a place where a person dwells. It "simply requires bodily presence as an inhabitant in a given place." Carlson v. District Court, 116 Colo. 330, 338, 180 P.2d 525, 530 (1947). Construing the phrase "residents of a household," this court has found that no one factor by itself is determinative. Factors that should be considered include: the subjective or declared intent of the individual; the formality or informality of the relationship between the individual and the members of the household; the existence of another place of lodging; and the relative permanence or transient nature of the individual's residence in the household. Iowa National Mutual Insurance Co. v. Boatright, 33 Colo. App. 124, 516 P.2d 439 (1973). In contrast, domicile "requires bodily presence in that place coupled with an intention to make it one's permanent home." Carlson v. District Court, supra, 180 P.2d at 530.