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 The identification of a family member as a head of the household is primarily based on his or her family relationship and duty to support the driver rather than place of residency. In fact, both parents can be considered a head of household under the doctrine. Johnson v. Steverson, No. W1999-00627-COA-R3-CV, 2000 Tenn. App. LEXIS 611, 2000 WL 1285282 (Tenn. Ct. App. Aug. 30, 2000). In Woodfin v. Insel, 13 Tenn. App. 493 (Tenn. Ct. App. 1931), the plaintiffs sued a grandmother who lived with her adult daughter and minor grandson after the grandson was involved in a collision while driving the grandmother's car. The appellate court's determination that the grandmother was not the head of the household was based in part on the finding that she owed her children or grandchildren no duty of support. Id. at 499. In Adkins v. Nanney, 169 Tenn. 67, 82 S.W.2d 867 (Tenn. 1935), the father was sued after his adult son was involved in an accident while driving the father's car. Although the son lived with the father, the son was self-supporting. Id. at 867-68. Because the son was not subject to the father's control and ...

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