N.C. Farm Bureau Mut. Ins. Co., Inc. v. Martin, 376 N.C. 280

Jan. 6, 2014 auto collision in Virginia Beach injured Jean Martin and her daughter Marina; the tortfeasor’s insurer paid $25,000 each (policy limits).
Farm Bureau had paid medical-payments and underinsured-motorist (UIM) benefits under a policy issued to Jean and David, but defendants also sought coverage under a separate Farm Bureau policy issued to Mary Martin (their mother/grandmother).
Mary’s policy defined “family member” as a person related to the named insured who is a “resident of your household”; the policy did not define “resident” or “household.”
Mary owned a 76-acre farm with two separate, standalone houses ~100 feet apart (different addresses and PO boxes); Mary lived in the main house; Jean and Marina lived in the guest house, kept separate belongings, and primarily lived separately though they visited daily and shared chores/expenses.
Farm Bureau sought a declaratory judgment denying coverage under Mary’s policy; trial court granted summary judgment to Farm Bureau; the Court of Appeals affirmed in a divided opinion; defendants appealed to the North Carolina Supreme Court.
The Supreme Court held that Jean and Marina were not “residents” of Mary’s “household” as a matter of law and affirmed summary judgment for Farm Bureau.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jean and Marina were "residents of Mary’s household" under Mary’s policy	Farm Bureau: No — they lived in a separate dwelling, with separate address/PO box and never lived under the same roof; thus not "residents."	Jean/Marina: Yes — close daily interaction, shared meals/chores, Mary paid many household/farm expenses and provided housing; intent to form a common household.	Held: No — a family member seeking coverage must have actually lived in the same dwelling for a meaningful period and shown intent to form a common household; here they never lived under the same roof, so no coverage.
Whether a special "family-farm" rule or broader Paschal test allows separate on-farm dwellings to be one household	Farm Bureau: No special exception; ordinary meaning requires dwelling shared.	Jean/Marina: Paschal supports treating relatives on contiguous farm properties as one household despite separate dwellings.	Held: No family-farm exception; Paschal (Court of Appeals) is not binding and cannot eliminate the threshold that parties must have actually lived together.
Whether summary judgment was appropriate	Farm Bureau: Yes — undisputed facts and plain policy language resolve coverage as a matter of law.	Jean/Marina: The inquiry is fact-intensive and context-dependent, so summary judgment is improper.	Held: Summary judgment appropriate; no genuine issue of material fact and de novo review.

Jamestown Mut. Ins. Co. v. Nationwide Mut. Ins. Co., 266 N.C. 430 (1966) (favored use of ordinary-dictionary meanings in defining “resident” for insurance policies)
Barker v. Iowa Mut. Ins. Co., 241 N.C. 397 (1955) (college son still a resident of father’s household where supported and living arrangements showed continued residence)
Newcomb v. Great Am. Ins. Co., 260 N.C. 402 (1963) (plaintiffs were residents of same household where they lived and stayed with insured at time of loss)
Jamestown Mut. Ins. Co. v. Nationwide Mut. Ins. Co., 266 N.C. 430 (1966) (factors showing actual residence and intent to form common household)
N.C. Farm Bureau Mut. Ins. Co. v. Paschal, 231 N.C. App. 558 (2014) (Court of Appeals decision taking a broader, fact-specific approach that did not require prior cohabitation)
Lunsford v. Mills, 367 N.C. 618 (2014) (plain language of policy controls interpretation)
Woods v. Nationwide Mut. Ins. Co., 295 N.C. 500 (1978) (policy terms must be harmoniously construed and given ordinary meaning)