Alexandre v. National Union Fire Insurance Co. of Pittsburgh, No. 21-1140 (1st Cir. 2022)
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The First Circuit affirmed the decision of the district court upholding Defendant National Union Fire Insurance Company of Pittsburg, PA's denial of accidental death insurance benefits to Plaintiff following her husband's death because he had committed suicide, holding that the district court did not err.
Plaintiff enrolled in an accidental death and dismemberment insurance policy, an employer-sponsored welfare plan affording participants like Plaintiff rights and protections under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. Plaintiff's husband was insured for a death benefit, with Plaintiff named as the beneficiary. After Plaintiff's husband fell nine stories from a hotel balcony and died, Plaintiff submitted a claim under the policy for accidental death benefits. Defendant denied benefits, concluding that Plaintiff's husband committed suicide, precluding benefits. Plaintiff filed suit under section 502(a)(1)(B) of ERISA seeking the benefits provided for under the policy. The district court granted summary judgment for Defendant. The First Circuit affirmed, holding that Defendant's denial of accidental death benefits was not arbitrary, capricious, or an abuse of discretion.
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