Electric Ins. Co. v. Jessica Gaudet, 692 F. App'x 459

Crane lived with his grandmother in Phoenix; Electric insured her household.
Crane allegedly killed Gaudet on January 26, 2012, after leaving the grandmother’s home.
Electric might defend or indemnify Crane depending on whether Crane was a resident of the grandmother’s household on January 26.
Electric sued for declaratory relief to establish no duty to defend or indemnify Crane; district court granted summary judgment for Electric.
Gaudets appealed, challenging jurisdiction and the merits of summary judgment.
Court held there was subject-matter jurisdiction and Crane was not a resident on the relevant date; summary judgment affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction under the Declaratory Judgment Act	Gaudets assert a real controversy existed.	Electric contends no actual controversy since no duty on the facts.	Jurisdiction existed; actual controversy present.
Crane's residence as that of the household	Gaudets argue policy could cover Crane as a resident.	Electric argues Crane ceased being a resident after December 6, 2011.	Crane was not a resident on January 26, 2012; no coverage under the policy.

Md. Cas. Co. v. Pac. Coal & Oil Co., 312 U.S. 270 (1941) (actual controversy required for declaratory relief)
Aetna Life Ins. Co. of Hartford v. Haworth, 300 U.S. 227 (1937) (actual controversy and apprehension of liability)
Yokeno v. Mafnas, 973 F.2d 803 (9th Cir. 1992) (jurisdictional and factual considerations for subject-matter jurisdiction)
JustMed, Inc. v. Byce, 600 F.3d 1118 (9th Cir. 2010) (de novo review of state-law questions by federal courts)
Weiner v. San Diego County, 210 F.3d 1025 (9th Cir. 2000) (review of summary-judgment decisions on appeal)
Mendota Ins. Co. v. Gallegos, 302 P.3d 651 (Ariz. Ct. App. 2013) (Arizona’s household determination via totality of relationships)