Allstate Insurance Co. v. Patterson, 231 Va. 358, 344 S.E.2d 890 (Va. 1986) involved a twenty-six-year-old who was injured in a motorcycle accident.
Prior to the accident, he had been living off-and-on for a few years at his motorcycle gang's clubhouses and with friends, all the while maintaining his bedroom at his parents' home, keeping the bulk of possessions there, using his parents' address on his official papers, subjectively considering it as his home, and, in fact living there approximately ten percent of the time before the accident.
The court held that the son was not a resident of his parents' home. See 344 S.E.2d at 893.
According to the court, "while a person's intention to become a member of a particular household need not be coupled with continuous residence, the intention must be accompanied by a reasonable degree of regularity in the person's residential contacts with the household; casual, erratic contacts are not sufficient." Id.