(dissenting).
I respectfully dissent.
I agree with the majority that the drop-down limit on bodily-injury coverage for resident family members is valid and enforceable in Minnesota. But under the applicable case law and the undisputed facts on this case, I would hold that Aven Frey was a resident of her parents’ household at the time this accident occurred.
In determining whether an individual is a resident relative of an insured’s household, the supreme court has set out three factors to consider, including whether the relative was
*348(1)[ljiving under the same roof; (2) in a close, intimate and informal relationship; and (3) where the intended duration is likely to be substantial, where it is consistent with the informality of the relationship, and from which it is reasonable to conclude that the parties would consider the relationship “... in contracting about such matters as insurance or in their conduct in reliance thereon.”
Firemen’s Ins. Co. of Newark v. Viktora, 318 N.W.2d 704, 706 (Minn.1982) (quoting Pamperin v. Milwaukee Mut. Ins. Co., 55 Wis.2d 27, 197 N.W.2d 783, 788 (1972)). Later, this court listed five factors to be considered, including:
(1) age of the person;
(2) whether a separate residence is established;
(3) self-sufficiency of the person;
(4) frequency and the duration of the stay in the family home; and
(5) intent to return.
Wood v. Mut. Serv. Cas. Ins. Co., 415 N.W.2d 748, 750 (Minn.App.1987), review denied (Minn. Feb. 12,1988).
Before applying these factors to this case, it is instructive to briefly review cases in which our courts have addressed this issue. First, cases in which the relative was determined not to be a resident will be analyzed.
In one such case, a 19-year-old relative was involved in an accident while driving an uninsured vehicle owned by his brother, who lived in the family home near Marshall with his parents. Van Overbeke v. State Farm Mut. Auto. Ins. Co., 303 Minn. 387, 387-90, 227 N.W.2d 807, 808-09 (1975). The district court found that when the relative was emancipated, provided for his own financial needs with no assistance from his parents, resided, was employed and went to school in Mankato, and intended Mankato to be his residence, he was not a resident of his brother’s household. Id. at 391-92, 227 N.W.2d at 810. The supreme court, upholding the findings as supported by the evidence, ruled that the fact that the relative continued to use his parents’ address as a mailing address for some purposes did not refute the findings by the district court that he resided in Mankato, rather than at the family home, at the time of the accident. Id.
In another such case, a recent high school graduate sought coverage as a resident relative under his parents’ policy after an accident. French v. State Farm Mut. Auto. Ins. Co., 372 N.W.2d 839, 840 (Minn.App.1985). After graduation, French had moved to an apartment, earning his living as a construction worker. Id. Although he moved back to his parents’ home for a few months after the construction season ended, he left again, due to his parents’ concern about the hours he kept. Id. He then stayed with friends or slept in his car for several months. Id. French was financially independent, did not have a key to his parents’ home, did not sleep there, and did not call or visit until shortly before the accident, when he enlisted in the Navy and joined his parents for a farewell dinner. Id. The district court granted summary judgment in favor of the insurer, determining based on these undisputed facts that French was not a resident of his parents’ home at the time of the accident. Id. at 843. The fact that French used his parents’ address on his driver’s license, a lapsed insurance policy, and his automobile registration was not determinative. Id. at 840, 843.
There are several cases that involve facts similar to the present case, in which a college student lived away from his or her parents while attending college, visited the family home during holidays and breaks, and was not financially self-supporting. In *349one such case, at the time of the accident, the 24-year-old college student attended the University of Minnesota, and lived off-campus in a duplex. Skarsten v. Dairyland Ins. Co., 381 N.W.2d 16, 17 (Minn.App.1986), review denied (Minn. Mar. 27, 1986). She returned to the family home one or two weekends a month and on holidays, where she had her own room and left some of her belongings and which she considered to be her permanent address. Id. at 18. Although employed at various jobs since high school, Skarsten had never been self-sufficient. Id. She received some student loans and grants and was supported by her father, who claimed her as a dependent on his tax returns for five of the six previous years. Id. On these undisputed facts, this court held as a matter of law that she resided in the family home. Id. at 17, 20. In addition to the above facts, this court noted that the policy named the college student as an insured on the family car, which was strong evidence that both Skarsten and her parents considered her to be a member of the household. Id. at 19; see Morgan v. Ill. Farmers Ins. Co., 392 N.W.2d 37, 40 (Minn.App.1986) (following Skarsten on similar facts and holding that where college student often lived at parents’ home, stored personal possessions there, was financially supported by her parents, and had an intimate relationship with them resulted in a determination that the student was a resident relative), review denied (Minn. Oct. 22, 1986).
Schoer v. W. Bend Mut. Ins. Co., 473 N.W.2d 73, 74, 76 (Minn.App.1991), involved a 21-year-old college student who lived in and attended a technical institute in Jackson at the time of the accident. He returned to his mother’s home in Wisconsin as often as possible and considered it to be his permanent residence. Id. at 76. He was not totally self-sufficient and received financial support from his mother when needed. Id. On this record, this court held that the jury finding that the young man was a resident of his mother’s home was not contrary to the weight of the evidence. Id. at 77.
Turning to the facts of this case and analyzing them in light of the Viktora and Wood factors, it is undisputed that Aven and her family did not reside full-time under the same roof. See Viktora, 318 N.W.2d at 706 (stating that residing under the same roof a factor). She was a fourth-year college student in Iowa, living in a college dormitory with her fiancé, and returning to her parents’ home for holidays and some school breaks. But the fact that Aven resided in a college dormitory does not necessarily mean that she was not a “resident” of her family’s home within the meaning of relevant case law; instead, all of the factors must be considered. See, e.g., Skarsten, 381 N.W.2d at 19 (holding college student was a resident despite fact she was not physically residing under same roof as insured); Schoer, 473 N.W.2d at 74, 77 (holding that college student was resident despite fact he resided away from family home while attending technical institute). As to the factor examining whether Aven and her family were in a close, intimate, and informal relationship, that is undoubtedly the case. See Viktora, 318 N.W.2d at 706 (stating that nature of relationship a factor).
Aven’s father, Stephen Frey, was the named insured on the policy providing coverage for the vehicle involved in this accident; Stephen, Aven’s mother Patricia, and her brother Nathan and sister Elsa, but not Aven herself, were named as operators on that policy. Stephen Frey was also the named insured on the Iowa policy that insured the vehicle that Aven used at college in Iowa, which was titled in her mother’s name, and on which Aven was the sole named operator.
Aven was 21 years old, and 21-year-old college students living at school have been *350considered residents of their parents’ homes. See, e.g., Schoer, 473 N.W.2d at 76 (holding fact that college student was 21 at the time of accident did not preclude him from being a resident of his mother’s household); Morgan, 392 N.W.2d at 38 (holding that college student, who was 21 years old at the time of the accident, was considered a resident of her parents’ household). But age, by itself, is not determinative. Emancipated individuals who were younger than 21 have been held to not be a resident of their parents’ household. See, e.g., Van Overbeke, 303 Minn. at 392, 227 N.W.2d at 810 (holding that emancipated 19-year-old was not a resident of his parents’ household); French, 372 N.W.2d at 843 (holding that the young age of relative, who had graduated from high school the year before the accident, might ordinarily weigh in favor of finding him to be a resident of parents’ household, but the fact that he was emancipated led to the conclusion that he did not reside with parents at time of accident).
The financial self-sufficiency of the individual is a very significant factor in determining whether the individual is a resident relative. See Wood, 415 N.W.2d at 750 (setting out self-sufficiency as a factor). When young adults were self-supporting, whether in college or not, they were found to not be residents of their parents’ homes. See, e.g., Van Overbeke, 303 Minn. at 392, 227 N.W.2d at 810 (holding that student who rented his own apartment, provided for all his own financial needs with no assistance from his parents, worked, and attended school was not a resident of parents’ home); Fruchtman v. State Farm Mut. Auto. Ins. Co., 274 Minn. 54, 57, 142 N.W.2d 299, 301 (1966) (holding that 27-year-old son who had been self-supporting since high school, had completed college and medical school, and was in army was not resident of parents’ household); French, 372 N.W.2d at 843 (holding that relative who had been totally self-supporting and did not receive money from parents was not resident of parents’ home).
When young adults were not self-supporting or relied on their parents for some support, residency has generally been found. Schoer, 473 N.W.2d at 76 (holding that college student who was not totally self-supporting and received some financial support from mother was resident of mother’s household); Wood, 415 N.W.2d at 751 (holding that where relative who joined army at 17 and depended on parents for some support, although he sent most of his money home and his parents could use it or send it to him as needed, was resident of parents’ household); Morgan, 392 N.W.2d at 39 (holding that college student who received financial support from parents, who claimed student as a dependent on their tax returns, was resident relative); Skarsten, 381 N.W.2d at 18-19 (holding that unemployed college student who was supported by her father, who claimed her as a dependent on tax returns for five of six previous years, but who also received student loans and grants, was resident relative). Here, it is undisputed that Aven’s parents financially supported her, paying for her room, board, and tuition at college, as well as providing her with a car and insuring it. While Aven held several part-time jobs while at college, including working at the college dining hall, a veterinary hospital, and a café, she never earned enough income to pay state or federal income tax or to be financially self-sufficient.
After considering the relevant case law and the facts of this case, I would conclude that as a matter of law Aven was a resident of her family’s home when this accident occurred.