Spangler v. Armstrong
In Spangler v. Armstrong, 201 W.Va. 643, 499 S.E.2d 865 (1997) (per curiam), the Court addressed a question regarding whether relatives of an insured were "residents of the insured's household."
The relatives lived in a house owned by the insured. However, the relatives paid the mortgage, taxes and utilities on the house.
Furthermore, the house was separate from the property on which the insured lived, and the insured visited his relatives only once or twice a month.
On these facts, the Court concluded that the word "household" in the disputed insurance policy was clear and unambiguous, and held that the relatives were not members of the insured's household.
In Spangler, the Court stated that "liability policies providing coverage for members of an insured's 'household' generally include persons who live under the same roof, but not those who live in separate houses." 201 W.Va. at 646, 499 S.E.2d at 868 .