Michael Dickman Discusses Appeals Court Ruling Limiting Homeowner’s Coverage for Adult Family Members

January 28, 2026

The Massachusetts Appeals Court has ruled that a homeowner’s insurance policy did not cover a $300,000 personal injury judgment against an adult grandson who was allegedly financially dependent on his grandmother. Reversing a Superior Court decision, the Appeals Court held that financial dependence alone is not enough to establish that an adult family member qualifies as an insured “resident of the household” under a homeowner’s policy.

Michael Dickman discussed the ruling with Massachusetts Lawyers Weekly:

“[The plaintiff] was pushing just the financial dependency piece, but it’s pretty clear that the other cases the court cited said this is a much more expansive analysis that needs to be undertaken to see if somebody who is not specifically named as an insured has coverage in a case like this.”

From a practical standpoint, Michael said the decision underscores the need for plaintiffs’ attorneys to be proactive early in a case when evaluating potential insurance coverage.

He noted that Rule 26(b)(2) of the Massachusetts Rules of Civil Procedure is “a great tool for understanding the insurance landscape in a case,” adding that, taken together with the court’s multi-factor analysis, the ruling offers litigators a clear roadmap for assessing and improving their chances of securing coverage.

Read the article “PI defendant not insured by grandmother’s homeowner’s policy” on the Massachusetts Lawyers Weekly website (subscription required).