Midwest Mut. Ins. Co. v. Titus
In Midwest Mut. Ins. Co. v. Titus, 849 P.2d 908, 910 (Colo. Ct. App. 1993), a Colorado court focused on intent and stated a "consideration of all relevant circumstances must reveal 'some intended presence in the insured's home.'"
The court listed the factors it would take into account in determining whether an individual is a resident of a household to include the "subjective or declared intent of the individual, the relation between the individual and the members of the household, the existence of a second place of lodging, and the relative permanence or transient nature of the individual's residence in the household." Midwest, 849 P.2d at 910.
The child's status as a minor is just one factor to be considered. Id. The court also recognized that a child of divorced parents is a resident of the household in which she actually lives but the child may reside in more than one household. Id.