In the payment of mutual benefits to the family of the holder of a certificate, a step father, not a member of the insured's house hold, was held not a member of his family ; Supreme Lodge Order of Mutual Protection v. Dewey, 142 Mich. 666, 106 N. W. 140, 3 L. R. A. (N. S.) 334, 113 Am. St. Rep. 596, 7 Ann. Cas. 681. In mutual benefit statutes "family" is an expression of great flexibility. It may mean the husband and wife, having no children and living alone together, or it may mean children or wife and children, or blood relatives, or any group constituting a distinct domestic or social body ; Carmichael v. Ben. Ass'n, 51 Mich. 494, 16 N. W. 871. It may apply to blood relatives, even though living apart from the applicant and having families of their own. It may apply to those who are neither relatives by consanguinity or affinity, provided they are of the household of the applicant and maintaining the rela tions usual in families united by blood ; Carmichael v. Ben. Ass'n, 51 Mich. 494, 16 N. W. 871; Simcoke v. Grand Lodge of A. 0. U. W. of Iowa, 84 Ia. 383, 51 N. W. 8, 15 L. R. A. 114; Spear v. Robinson, 29 Me. 531; Klotz v. Klotz, 22 S. W. 551, 15 Ky. L. Rep. 183 ; Appeal of Folmer, 87 Pa. 133; Danielson v. Wilson, 73 III. App. 287 ; Carpenter v. Ins.
Co., 161 Pa. 9, 28 Atl. 943, 23 L. R. A. 571, 41 Am. St. Rep. 880 ; Norwegian Old People's Home Society v. Wilson, 176 Ill. 94, 52 N. E. 41.
In the construction of wills, the word fam ily, when applied to personal property, is synonymous with kindred or relations. It may, nevertheless, be confined to particular relations by the context of the will, or may be enlarged by it, so that the expression may in some cases mean children, or next of kin, and in others may even include relations by marriage ; Schoul. Wills 537. The primary meaning of the word family is children, and it must be so construed in all cases unless the context shows that it was used in a dif ferent sense ; Phillips v. Ferguson, 85 Va. 509, 8 S. E. 241, 1 L. R. A. 837, 17 Am. St. Rep. 78. It has been more commonly held that parents are not included in the term ; 8 Yes. 604 ; 2 Redf. Wills 73 ; 5 Maule & S. 126 ; Spencer v. Spencer, 11 Paige (N. Y.) 159 ; it may include a wife as well as children ; Bowditch v. Andrew, 8 Allen (Mass.) 339. A statute providing that real estate shall not go "out of the family" restricts the descent to the issue of the ancestor ; Den v. D'Hart, 3 N. J. L. 481. See HEAD OF A FAMILY.