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\\n\\nHomeowners Policy Requires Insured to Reside at Premises\\nShanice Currie had a homeowners insurance policy with State Auto \\nProperty & Casualty Insurance Company (State Auto). After two fires \\nseverely damaged her duplex in Milwaukee, Currie sought payment from \\nState Auto. State Auto denied the request for coverage, claiming that \\nthe duplex was not a "residence," and therefore was not covered by the \\npolicy. Currie sued State Auto. The district court granted summary \\njudgment to State Auto.\\n\\nIn Shanice Currie v. State Auto Property & Casualty Insurance \\nCompany, No. 22-2517, United States Court of Appeals, Seventh Circuit \\n(July 5, 2023) the USCA for the Seventh Circuit explained the meaning of\\n the terms "residence premises" and "reside."\\n\\nBACKGROUND\\n\\nCurrie purchased the previously abandoned duplex (the Property) from the\\n City of Milwaukee in the spring of 2018. She proceeded to install \\nelectricity and fill the bedroom with a dresser, mirror, clothing, and a\\n bed. Yet, at the time she acquired the policy the property had no \\nrunning water, kitchen appliances, no chairs or sofas in the living \\nroom, or a front door. Where a door should be, there was a wooden board \\nthat Currie would have to unscrew to enter the Property. Strangers came \\nand went, and Currie took no action to eject them.\\n\\nApart from sleeping at the Property two or three nights per month, \\nCurrie did not stay there. She bathed, prepared meals, kept personal \\nbelongings, and received mail at her two other addresses in Milwaukee.\\n\\nTHE POLICY\\n\\nThe homeowners policy Currie purchased from State Auto for the Property \\ncovered \\u201cresidence premises,\\u201d which the policy defined as: \\u201cThe two-, \\nthree-, or four-family dwelling where you reside in at least one of the \\nfamily units . . . on the inception date of the policy period shown in \\nthe Declarations and which is shown as the \\u2018residence premises\\u2019 in the \\nDeclarations.\\n\\nBecause the policy\'s inception date was September 15, 2018, Currie \\nneeded to reside in one of the units on the Property on that date for \\ncoverage to attach. She did not.\\n\\nTHE FIRES\\n\\nOn October 31 and on November 2, 2018, fires broke out at the Property, \\ncausing extensive damage. Currie informed State Auto that the Property \\nwas a total loss and sought full replacement value. State Auto denied \\nCurrie\'s claim, explaining that the Property was never her residence.\\n\\nDISCUSSION\\n\\nCurrie sued. The district court granted State Auto\'s motion for summary \\njudgment. \\n\\nThe address was not listed on her driver\'s license and her mail was sent\\n to a different location. Most telling, the Property was not secure. It \\nhad no door nor facilities to support normal life.\\n\\nAs a matter of law, Currie\'s Property was not a residence on the \\npolicy\'s inception date nor any time before or after. It was not covered\\n by the insurance policy, and the district court\'s grant of summary \\njudgment to State Auto was proper.\\n\\nZALMA OPINION\\n\\nInsurers will issue fire insurance on vacant property but will not do so\\n on a homeowners policy form. To protect the insurer the homeowners \\npolicy requires the insured to reside on the property. Since the \\nproperty was not sufficiently equipped for a person to reside in because\\n it had no door, no water and no other facilities to support normal \\nlife, Currie failed to fulfill the basic requirement for coverage: \\nresidence. Had the insurer been told the truth about the condition of \\nthe property it would never have agreed to the coverage. Because of the \\nresidence condition there was no need for the insurer to accuse the \\ninsured of fraud.\\n\\n(c) 2023 Barry Zalma & ClaimSchool, Inc.\\n\\n