Where You Reside: The Hidden Killer Exclusion in Your Homeowner Policy

Three words buried in the definitions section of your homeowner’s insurance policy have the power to eliminate your coverage entirely: “where you reside.”This is not a standard exclusion that appears in bold type under the exclusions section. It is embedded in a definition — the definition of “residence premises” — and most policyholders will never read it until the day their insurer uses it to deny a claim. The Independent Insurance Agents & Brokers of America (the “Big I”) has called this language a “catastrophic homeowners policy exclusion,” and for good reason.

Bill Wilson’s 2009 Big I white paper — “Where You Reside — The ‘Where’s Waldo?’ Catastrophic Homeowners Policy ‘Exclusion’ That Could Bankrupt Your Insureds”— brought national attention to this issue and documented roughly nine court decisions upholding denials and an equal number overturning them. The split has only deepened since.

The Policy Language at Issue

The standard ISO HO-3 homeowner’s policy — the most widely sold homeowner policy form in the United States — defines “residence premises” as the one-family dwelling “where you reside”and which is shown as the “described location” on the declarations page. This definition is the gateway to virtually all coverage under the policy. Your dwelling coverage (dwelling), other structures coverage (Other Structures), personal property coverage (personal property), loss of use coverage (Loss of Use), personal liability coverage (personal liability), and medical payments coverage (Medical Payments) all flow through the “residence premises” definition.

What makes this language so dangerous is what it does notsay. There is no separate exclusion that reads: “If you stop residing at the described premises, all coverage is void.” Instead, the coverage-defeating language is hidden inside a definition. Most policyholders — and many insurance agents — read the definitions section as merely describing the property being insured. They do not realize that the phrase “where you reside” can be interpreted as a continuing condition of coverage, one that must be satisfied at the time of every loss.

Critically, the term “reside” is almost never defined in the policy itself. This omission is at the heart of the legal battle that has unfolded across dozens of jurisdictions.

The Descriptive vs. Proscriptive Debate

The central legal question is whether the phrase “where you reside” is descriptive or proscriptive. This distinction determines whether millions of homeowners have coverage or not.

The Proscriptive (Coverage-Defeating) Reading

Under the proscriptive interpretation, “where you reside” establishes a continuing condition that the insured must satisfy at the time of each loss. Insurers argue that dictionary definitions of “reside” uniformly require physical presence at a location plus an intent to treat it as one’s home. If the policyholder is not actually residing at the described premises when the loss occurs, the property does not qualify as a “residence premises,” and coverage does not exist. Under this reading, a homeowner who moves to a nursing home, goes on an extended trip, or relocates for work — while continuing to pay premiums on the home — may find that their coverage has silently evaporated.

Insurers also argue risk assessment: the premium was calculated for an owner-occupied dwelling. An unoccupied home presents higher risks — vandalism, undetected water leaks, fire hazards — that were never priced into the policy.

The Descriptive (Coverage-Preserving) Reading

Under the descriptive interpretation, “where you reside” merely identifies which property is being insured at the inception of the policy. It is a label — a way of pointing at the insured property — not a condition that must be continuously maintained. The policyholder designated this property as their residence when they purchased the policy, and that designation does not dissolve simply because life circumstances change.

This interpretation is supported by the doctrine of contra proferentem, which requires that ambiguous policy language be construed against the insurer who drafted it. If “where you reside” can reasonably be read as either a description or a condition, California law — and the law of most states — requires that the interpretation favoring coverage prevail. The insurer drafted the policy. If it intended “where you reside” to be a condition of coverage, it could have said so explicitly: “Coverage applies only while you are physically residing at the described premises.” It did not.

Multiple courts have also recognized that a person can “reside” in more than one location for insurance purposes — a principle that directly benefits a nursing home resident who maintains ties to their home, keeps belongings there, and intends to return.

The Nursing Home Problem

No scenario illustrates the cruelty of the proscriptive interpretation more starkly than the nursing home problem. Consider the following hypothetical, drawn directly from the Big I’s analysis of this issue:

The Big I has made several powerful arguments for why coverage should exist in this scenario. Their analysis deserves to be quoted at length, because it captures the scope of the problem:

The “where you reside” requirement is not set forth clearly and conspicuously as an exclusion or condition — it is buried in a definition. The policyholder had no reasonable expectation that moving to a care facility would void all coverage on the home she had insured for decades.

The Big I further argued that the “where you reside” language should be understood as establishing eligibility for the policy at inception, not as a continuing conditionof coverage. When the insurer issued the policy, it verified that the applicant resided at the premises. That eligibility criterion was satisfied. Transforming it into an ongoing condition that the policyholder must satisfy at the moment of every loss is a fundamentally different interpretation — and one that was never disclosed to the policyholder.

The most devastating argument is the unconscionability argument. The Big I posed a hypothetical that illustrates the problem clearly:

Under the proscriptive reading, an insurer could deny coverage to the elderly homeowner whose home burns while she is in a nursing home — but would be required to cover the identical home if it were being used as a meth lab by squatters. In the meth lab scenario, the property is still the “described location” on the declarations page; the only question is whether the named insured “resides” there. The meth lab operator has no coverage because he is not the named insured. But the named insured has no coverage either, because she is no longer residing there. The home burns either way. In one scenario (the nursing home), the insurer pockets 30 years of premiums and pays nothing. In the other (the meth lab), the insurer would be obligated to pay. The result is absurd, and unconscionable.

Case Law: A Genuine Split Across Jurisdictions

This issue has been litigated across the country, and the results are far from uniform. Courts have reached conflicting conclusions about whether “where you reside” is a condition of coverage or merely a descriptive identifier. The outcome often turns on the specific facts — particularly whether the insured maintained ties to the property, whether they rented it out, and whether the insurer knew about the change in living circumstances.

Courts That Found Coverage for the Policyholder

Durkheimer v. Safeco (D. Or. 2025):The Durkheimers owned homes in Portland, on the Oregon coast, and in Carmel, California, all insured by Safeco. During the January 2024 freeze, their Portland home suffered hundreds of thousands of dollars in water damage from burst pipes. Safeco raised an affirmative defense that the Durkheimers did not “reside” at the Portland home. On February 12, 2025, Magistrate Judge Stacie Beckerman recommended striking Safeco’s affirmative defense, finding the “residence premises” language was intended to identify the property, not to create a coverage condition. On April 1, 2025, Judge Michael Simon adopted the recommendation and struck the defense as insufficient as a matter of law.

Lamonica v. Hartford Insurance Co. of the Midwest, No. 5:19-cv-78 (N.D. Fla. 2020):The plaintiff inherited his mother’s home. He did not live there full-time but routinely returned, stayed at the house, and regarded it as the family homestead. Hartford denied a property claim, arguing the home was not his “residence premises.” The court denied Hartford’s motion for summary judgment, holding that the policy does not require the home to be the insured’s sole or even primary residence — “any residence will do.” The court distinguished this from cases where the insured rented out the property, noting that Lamonica never used it inconsistently with treating it as a permanent residence. The court also emphasized that Hartford had accepted premiums while knowing about the policyholder’s living arrangement, invoking the doctrines of estoppel and waiver.

Dean v. Tower Insurance Co. of New York, 19 N.Y.3d 1 (N.Y. 2012):In this decision from New York’s highest court, the Deans purchased a home and obtained a homeowner policy but had not yet moved in when damage occurred during renovations. Tower denied coverage because the Deans did not “reside” at the property. The Court of Appeals held that the term “reside” was not defined in the policy, making “residence premises” ambiguous under the circumstances. It reversed summary judgment for the insurer, finding the insured’s reasonable expectations were relevant.

Craft v. New York Central Mutual Fire Insurance Co.(N.Y. App. Div. 3d Dep’t, 2017):The plaintiff and her husband built their home in 1967. When the home was damaged by fire in 2014, the plaintiff’s daughter-in-law was residing in the premises, but not the named insured. The court held that because the policy did not define “reside,” the term was ambiguous, and noted thata person can have more than one residence for insurance purposes.

Shank v. Safeco Insurance Co. of America, No. 2:15-cv-09033 (S.D. W. Va. 2016):A married couple owned their primary home and inherited a second home from a relative. They used the second home weekly — cooking, watching TV, using the workshop, collecting mail. A fire destroyed it. Safeco denied the claim based on the “residence premises” definition. The court ruled that Safeco’s “residence premises” provision was more restrictive than permittedunder West Virginia law. West Virginia requires fire policies to conform to the Standard Fire Policy, which only suspends coverage when a building has been “vacant or unoccupied beyond a period of sixty consecutive days.” Requiring “residence” imposed a stricter standard, and the court held Safeco breached the policy.

Lundquist v. Allstate Insurance Co., No. 2-99-0863 (Ill. App. 2d Dist. 2000):The Lundquists moved to Oregon but had not completed the sale of their Rockford, Illinois, home when a loss occurred. The policy defined “dwelling” as the structure “where you reside.” The Illinois Appellate Court held that while physical presence is a component of residence, the degree of presence required was unclear, making the provision subject to more than one reasonable interpretation and therefore ambiguous. Allstate could not deny coverage based on its definition of “reside.”

Epstein v. Hartford Casualty Insurance Co., 566 So. 2d 331 (Fla. 1st DCA 1990):The Florida First District Court of Appeal held that “residence” is ambiguous and does not require the property to be the insured’s sole or primary residence.

Courts That Denied Coverage

Pour v. Liberty Mutual Personal Insurance Co., No. 24-1824 (8th Cir. 2025):The Eighth Circuit held that the “where you reside” language was a condition of coverage. The policyholder had relocated from Minnesota to Georgia, establishing a new primary residence in another state while maintaining the insured property. The court found that “reside” required physical presence and an intent to remain, and the claim was denied.

Arguelles v. Citizens Property Insurance Corp., 278 So. 3d 108 (Fla. 3d DCA 2019): Arguelles owned a condominium insured by Citizens. At the time of a plumbing leak, he was living in New York and the condo was occupied by two tenants. The policy defined “residence premises” as “the unit where you reside.” The Third District Court of Appeal affirmed summary judgment for Citizens, finding the policy language unambiguous. The distinguishing factor: Arguelles was not merely absent from the property — he had rented it out, which is inconsistent with any reasonable claim of “residing” there.

American Risk Insurance Co. v. Serpikova, 522 S.W.3d 497 (Tex. App. — Houston [14th Dist.] 2016, pet. denied):The Texas Court of Appeals ruled that coverage required the insured to reside at the property or intend to reside there within 60 days of the policy’s effective date. Neither condition was met. The Texas Supreme Court denied the petition for review.

Adkisson v. Safeco Insurance Co. of Indiana, No. 6:23-cv-00146 (E.D. Tex. 2024):Adkisson owned a home in Longview, Texas, which suffered water damage during a historic freeze. He primarily lived in Godley, Texas, closer to his workplace. The Longview home was largely unfurnished — an air mattress, a TV, and minimal appliances. Utility usage was minimal. The court ruled for Safeco, finding Adkisson did not “reside” at the Longview property.

Davani v. Travelers Personal Insurance Co., No. 22-1244 (D. Kan. 2023):The insured never actually lived at the insured premises. The court held that “residence” requires physical presence at the location and an intent to remain for an indefinite period. Summary judgment was granted for Travelers.

Heniser v. Frankenmuth Mutual Ins. Co., 534 N.W.2d 502, 449 Mich. 155 (Mich. 1995):The Michigan Supreme Court found the policy unambiguous and denied coverage for a vacation home where the insured admitted he did not live at the property and did not intend to live there. This case is now frequently cited in Michigan insurance law. The dissent is notable: the dissenting justice argued that “dwelling used principally for dwelling purposes” language was “not clear and explicit enough to create a warranty.”

The ISO Fix: Endorsements HO 06 48 and HO 06 49

The insurance industry itself has acknowledged that the “where you reside” language creates an unfair coverage gap. In 2015, the Insurance Services Office (ISO) — the organization that drafts the standard policy forms used by most insurers — issued a countrywide revision to address the problem.

HO 06 48: Residence Premises Definition Endorsement

This mandatoryendorsement, effective October 1, 2015 in most states, modifies the definition of “residence premises” so that the “where you reside” requirement is evaluated only “on the inception date of the policy period shown in the Declarations.”Once the policy incepts, the insured can move out — to a nursing home, to another state, anywhere — and the property remains a “residence premises” for the remainder of that policy period.

This is the most directly helpful development for the nursing home scenario. If the policyholder was residing at the home when the policy last renewed, coverage continues through the policy period even if a nursing home placement occurs mid-term.

HO 06 49: Broadened Residence Premises Definition Endorsement

This optionalendorsement goes further. It allows the insurer and policyholder to designate specific starting and termination dates during which the residency requirement is suspended entirely. It was designed for situations where the owner does not reside at the home at policy inception — homes being remodeled, transitional periods, and, critically, extended nursing home or care facility placements.

The availability of HO 06 49 varies by carrier and by state. Not all insurers offer it, and not all agents know to ask for it. But it exists, and it should be requested whenever a policyholder’s living situation has changed or is expected to change.

Practical Guidance: How to Protect Yourself

Whether you are a policyholder, a family member managing an elderly parent’s affairs, an insurance agent, or a practitioner, this issue requires proactive attention. The following steps can significantly reduce the risk of a coverage denial based on the “where you reside” language.

Step 1: Notify Your Agent Immediately

The moment a homeowner is admitted to a nursing home, assisted living facility, or similar care facility — whether voluntarily or involuntarily — their insurance agent should be notified in writing. This is the single most important step. Written notification creates a record that the insurer was aware of the change in circumstances and continued to accept premiums. If a claim is later denied, this creates a powerful estoppel argument: having accepted premiums with knowledge of the situation, the insurer cannot disclaim coverage when it comes time to pay. Save every premium notice, payment confirmation, renewal letter, and correspondence.

Step 2: Request the Residence Premises Endorsements

Ask your agent specifically about ISO endorsement HO 06 48 (Residence Premises Definition) and HO 06 49(Broadened Residence Premises Definition). If HO 06 48 is already on the policy — it has been mandatory since 2015 in most states — confirm that coverage is locked in through the current policy period. If the policyholder will still be in care at the next renewal, request HO 06 49 to suspend the residency requirement for a designated period.

Step 3: Consider Converting to a Dwelling Fire Policy

If the insurer will not add the broadened endorsement, or if the policyholder’s move to a care facility is permanent, the property can be re-insured under a Dwelling Fire policy(DP-1 or DP-3) rather than a homeowner policy. Dwelling Fire policies do not require the named insured to reside at the property. They are the standard product for rental properties, seasonal homes, and unoccupied dwellings. The coverage may differ — often more limited liability coverage, and possibly named-perils rather than open-perils on a DP-1 — but the property protection remains in place. This is the recognized fallback when the homeowner policy becomes untenable due to a residency issue.

Step 4: Determine Whether a Family Member Still Resides in the Home

If a spouse, adult child, or other family member continues to live at the insured property, the “where you reside” problem may not arise at all. Under many policy forms, an “insured” includes family members who reside in the household. If any insured still resides at the property, the residence premises definition remains satisfied. Even if the policy defines “you” as only the named insured and spouse, having a family member occupy the home strengthens the argument that the property remains a “residence premises.”

Step 5: Maintain Evidence of Continuing Ties

If the homeowner cannot return to the property, maintain as many ties as possible:

• Keep the home address as the legal and mailing address
• Maintain voter registration at the home address
• Keep belongings, furniture, and personal effects in the home
• Continue all utilities
• Have family members regularly maintain the property — mowing, snow removal, checking for issues
• Do not change the address on legal or financial documents
• Document the homeowner’s stated intent to return

If the homeowner’s health allows it, periodic returns to the home — even brief stays — can help establish an ongoing connection. However, courts have found that “sporadic interactions” may be insufficient when the insured has taken affirmative steps to disassociate from the property. Return visits should be genuine and documented.

Step 6: If You Rent the Property, Convert the Policy First

Families often need rental income from the property to help pay for the care facility. That is understandable — but renting the property while maintaining a homeowner policy is the single biggest factor that courts use to rule against coverage. In Arguelles, the Florida court denied coverage specifically because the insured had rented out the property to tenants while keeping a homeowner policy. Once a property is rented under a homeowner policy, the insured has unambiguously stopped “residing” there, and the proscriptive interpretation becomes nearly impossible to overcome.

The solution is not to avoid renting altogether — it is to convert the insurance before placing tenants. If the family decides to rent the property:

• Contact the insurance agent and obtain a landlord or dwelling fire policy (DP-1 or DP-3) beforeany tenant moves in. A landlord policy is designed for non-owner-occupied rental properties and does not contain the “where you reside” language.
• Cancel or replace the existing homeowner policy.Do not maintain the old homeowner policy in the elderly insured’s name while renting to tenants. If a loss occurs, the insurer will deny the claim under the homeowner policy because the named insured does not reside there, and the family will have paid premiums on a worthless policy. The old homeowner policy must be replaced with the appropriate landlord or dwelling fire form.
• Consider requiring tenants to carry renter’s insurance.A landlord policy covers the dwelling and the owner’s liability, but it does not cover the tenant’s personal property or the tenant’s liability to others. Requiring tenants to carry an HO-4 renter’s policy protects everyone.

The key point: renting is not fatal to the property being insured. It is fatal to a claim under a homeowner policy. Get the right policy for the right situation, and the property stays covered.

Step 7: Review the Vacancy Provisions Separately

The “where you reside” issue is distinct from the 60-day vacancy exclusion that exists in most homeowner policies. Even if you win the residency argument, the insurer may assert the separate vacancy exclusion if the home has been unoccupied for an extended period. Some insurers offer a vacancy permit endorsement that extends coverage during periods of vacancy. This does not address the residence premises definition directly, but it prevents a separate vacancy-based denial. Review both provisions and address them independently.

Step 8: Transferring the Home Into a Trust — Estate Planning Meets Insurance

Many families place an elderly parent’s home into a trust as part of estate planning — often long before a nursing home placement becomes necessary. A common arrangement is a family trust or revocable living trustwhere the home is transferred to the trust, the original homeowner retains a life estate(the right to live in the property or receive rental income from it during their lifetime), and the remainder interest passes to the heirs upon the homeowner’s death. This is a well-established estate planning tool that can help avoid probate, facilitate the orderly transfer of assets, and — in certain trust structures — assist with Medicaid planning.

But the estate plan and the insurance policy exist in different universes, and a trust that works perfectly as an inheritance vehicle can create serious insurance problems if the policy is not updated to match.

The Insurable Interest Trap

This is the issue that catches the most families off guard. When a homeowner transfers their property into a trust but retains a life estate, something fundamental changes: the original homeowner no longer owns the property outright. They own a life estate — the right to use or occupy the property for the remainder of their lifetime. The trust (and ultimately the remainder beneficiaries — typically the heirs) holds the remainder interest. Together, the life estate and the remainder interest make up full ownership. Separately, neither one represents the full value of the home.

This matters enormously for insurance, because an insurer is only obligated to pay based on the named insured’s insurable interestin the property. If the policy still names the original homeowner as the sole named insured, and a total loss occurs, the insurer may argue that the named insured’s insurable interest is limited to the value of the life estate — not the full replacement cost of the dwelling. The value of a life estate is calculated actuarially, based on the life expectant’s age. For an 85-year-old in a nursing home, the value of a life estate can be a small fraction of the property’s full value.

The result: the family set up a trust to preserve the home for the heirs, kept paying premiums on the homeowner policy, and then discovered after a fire that the policy would only pay the actuarial value of the life estate — potentially tens or hundreds of thousands of dollars less than the cost to rebuild.

Trust Types and Their Insurance Implications

Revocable living trust:The most common estate planning trust. The original homeowner (as grantor) can modify or revoke the trust at any time during their lifetime. Because the grantor retains control, most insurers will continue the homeowner policy with the trustee listed as the named insured. However, the “where you reside” problem still applies — the trust does not eliminate the residency requirement from a homeowner policy. If the grantor enters a nursing home and no one resides at the property, the same coverage gap exists regardless of the trust structure.

Irrevocable trust (including trusts with a retained life estate):This is where the insurable interest issue is most acute. The original homeowner has permanently transferred ownership to the trust and cannot take it back. If they retained a life estate, their interest in the property is limited to the right to use it during their lifetime — an interest that diminishes with age. The trust holds the remainder. The insurance must be rewritten with the trust as the named insured, and the policy type should reflect the actual occupancy status. If no one resides at the property, a dwelling fire policy (DP-1 or DP-3) naming the trust is the appropriate coverage. If a family member resides at the property, a homeowner policy naming the trust (with the residing family member as an insured) may work. This requires coordination between the elder law attorney and the insurance agent.

In either case:When a property is transferred into a trust, the insurance agent must be notified immediately so the policy can be updated. If the policy still lists the individual as the named insured after the trust becomes the legal owner, the insurer may deny a claim on the basis that the named insured no longer has an insurable interest — or has only a limited one. This is a separate and additional coverage trap that compounds the “where you reside” problem.

Practical Steps When a Home Is in a Trust

• Update the named insured on the policy to reflect the trust. This should happen at the time of the trust transfer, not after a loss.
• If the original homeowner enters a care facility and no one will reside at the property: Convert to a dwelling fire policy with the trust as the named insured. This eliminates both the residency problem and the insurable interest problem in one step.
• If a successor trustee or family member will reside at the property: The insurer may allow a homeowner policy with the trust as the named insured and the residing family member as an additional insured. This satisfies the residency requirement while preserving the trust’s full insurable interest.
• If the property will be rented out: A landlord or dwelling fire policy naming the trust as the insured is the correct product. Do not maintain a homeowner policy on a trust-owned rental property.
• Review the policy at every change in circumstance:Trust creation, nursing home admission, change of trustee, decision to rent, decision to leave the property vacant — each of these is a trigger to review and potentially restructure the insurance.
• Expect the insurer to request a copy of the trust document.This is normal and routine. When an insurer learns that a property is held in a trust — whether at the time of policy issuance, at renewal, or after a claim is filed — it will typically request a complete copy of the trust instrument. The insurer needs to verify who holds legal title, who the trustees and beneficiaries are, whether the trust is revocable or irrevocable, and what interest (if any) the original homeowner retained. All of this affects how the policy should be written and, after a loss, how the claim should be paid. Families should not be alarmed by this request, but they should be prepared for it — and they should understand that providing the trust document gives the insurer the information it needs to evaluate the insurable interest question. If there are concerns about the trust’s terms or how they may affect coverage, have the estate planning attorney review the trust document with the insurance implications in mind before it is submitted.

Additional Arguments for Practitioners

Attorneys handling a denied claim based on this language should consider:

• Contra proferentem:The ambiguity in “reside” — which is not defined in the policy — must be resolved in favor of coverage. Dean v. Tower (N.Y. 2012) and Lundquist v. Allstate(Ill. 2000) both turned on this principle.
• Estoppel and waiver: If the insurer or its agent knew the policyholder was in a care facility and continued to accept premiums without disclaiming coverage, estoppel may bar the denial. Lamonica relied on this.
• Reasonable expectations: No reasonable policyholder expects that a medical emergency will immediately terminate property coverage on the home they have insured for decades.
• Standard Fire Policy conformity:In states that require conformity with the Standard Fire Policy, the “residence premises” requirement may be more restrictive than the statutory framework allows. Shank v. Safeco(S.D. W. Va. 2016) is the leading authority on this argument.
• Review the declarations page:In some cases, the declarations page identifies the property by address alone without using the phrase “residence premises.” If the declarations page description does not incorporate the “where you reside” language, that is an additional argument against the insurer’s position.

Conclusion

The “where you reside” language is a coverage trap embedded in the most widely sold homeowner policy form in America. It is not flagged as an exclusion. It is not explained at the point of sale. It does not appear in the policy summary or outline of coverage. It sits quietly in the definitions section until the day a policyholder — often elderly, often in a care facility, often at the most vulnerable point of their life — files a claim and discovers that decades of faithfully paid premiums may have purchased nothing.

The case law is mixed, but the trend favors policyholders — particularly in cases involving involuntary absence, maintained ties to the property, and insurer knowledge of the living situation. Courts are increasingly reluctant to allow insurers to deny coverage based on definitional language that was never clearly disclosed as a condition of coverage. The doctrines of contra proferentem, reasonable expectations, estoppel, and unconscionability all weigh heavily in the policyholder’s favor.

ISO’s 2015 endorsements — HO 06 48 and HO 06 49 — represent the industry’s own acknowledgment that the original language was unfair. But these endorsements are not a complete fix. They require awareness, proactive requests, and in many cases agent involvement that may not happen without the policyholder or their family taking the initiative. State legislatures should consider legislation requiring insurers to notify policyholders that their coverage may be affected by a change in residency status. And insurance agents should affirmatively counsel their clients about this risk, particularly when clients are aging and may be approaching the point where a transition to a care facility is foreseeable.

Until those changes happen, the burden falls on policyholders and their advocates to identify this risk early, preserve their arguments, and push back hard when an insurer attempts to use three words in a definition to void decades of coverage.