Curtis Barnes v. 21st Century Premier Insurance Company, 965 N.W.2d 121

On Sept. 27, 2013 Curtis Barnes was injured in a car crash; his grandparents carried the applicable no-fault policy issued by 21st Century Premier Insurance Company (CPIC).
Barnes lived in the upstairs portion of a two-story family house; grandparents lived downstairs. The structure had separate entrances and separate utilities and mechanical systems, but interior doors (including the stairwell door) were generally unlocked and family members freely accessed both levels.
Barnes regularly used downstairs facilities (laundry, food, meals), kept personal effects in the home, contributed money toward household costs (disputed scope), had no written rental agreement, and used the house mailing address.
CPIC emphasized features indicating separate residences (kitchen, bathroom, meters, furnaces upstairs; Barnes paid some bills) and pointed to a 2010 insurance application in which the grandfather did not list Barnes as a household member.
Procedural posture: trial court denied CPIC’s motions for summary disposition and directed verdict; a jury found Barnes was domiciled in the same household as his grandparents; CPIC consented to entry of judgment but reserved the right to appeal the domicile rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether summary disposition (C)(10) should have been granted on domicile	Barnes: factual record shows one family unit under same roof; evidence created genuine fact issue	CPIC: upstairs unit functioned as a separate household as a matter of law	Denied; court found conflicting evidence and Workman factors supported submission to jury
Whether directed verdict should have been granted at close of plaintiffs’ proofs	Barnes: sufficient evidence for a reasonable jury to find single household/domicle	CPIC: plaintiffs failed to prove domicile; evidence showed independent residence	Denied; reasonable jurors could differ so issue for jury
Whether the jury verdict was against the great weight of the evidence (new trial)	Barnes: jury credibility findings supported by competent evidence	CPIC: verdict contradicted overwhelming evidence of two households	Denied and unpreserved (no new-trial motion); record contained competent evidence to support verdict

Workman v. DAIIE, 404 Mich 477 (1979) (articulates multi-factor test for determining whether a person is "domiciled in the same household")
Grange Ins. Co. of Mich. v. Lawrence, 494 Mich 475 (2013) (confirms Workman factors; domicile generally a question of fact)
Fowler v. Auto Club Ins. Ass'n, 254 Mich App 362 (2002) (carriage-house facts where adult child was found not domiciled in parents' household)
Hicks v. Automobile Club Ins. Ass'n, 189 Mich App 420 (1991) (upstairs/downstairs units treated as separate households where independent utilities, addresses, and rent existed)
Thomas v. Vigilant Ins. Co., 156 Mich App 280 (1986) (uses dictionary definitions and factual indicia to assess household status)
Dairyland Ins. Co. v. Auto-Owners Ins. Co., 123 Mich App 675 (1983) (additional factors for adult children with complex living arrangements)
Maiden v. Rozwood, 461 Mich 109 (1999) (courts may consider only substantively admissible evidence on summary disposition)