Boyer v. Schneider Electric Holdings, Inc., No. 19-3144 (8th Cir. 2021)
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Plaintiff sought life and accidental death benefits under her brother's insurance plan after he died in a single-vehicle crash. Unum Life paid plaintiff life insurance benefits, but denied her claim for accidental death benefits. Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA).
The Eighth Circuit reversed the district court's grant of summary judgment for plaintiff, concluding that the administrator's decision was supported by substantial evidence. The court explained that the evidence is sufficient to support a reasonable finding that the brother's speeding and improper passing contributed to the crash; the crime exclusion applies to "accidental losses;" and Unum Life's interpretation of the "crime" exclusion was reasonable because the brother's conduct constituted a crime under Missouri law. In this case, the brother was driving more than twice the legal speed limit and passing vehicles in a no-passing zone on a two-lane road in icy road conditions. Furthermore, Missouri's classification of improper passing and speeding as misdemeanor offenses reinforces the reasonableness of Unum Life's determination.
Court Description: [Colloton, Author, with Arnold and Kelly, Circuit Judges] Civil case - Insurance. Plaintiff sought accidental death benefits after the insured's decedent died in a single-car accident; the insurer denied accidental death benefits because the decedent was committing a crime - speeding and passing in a no-passing zone - at the time of the fatal crash. The district court concluded the insurer's interpretation of the "crime" exception in the plan was unreasonable and granted judgment for the the plaintiff. Held: the administrator's decision was supported by substantial evidence regarding the circumstances of the accident and the insurer's interpretation of the crime exclusion was reasonable as the conduct constituted a crime under Missouri law because the conduct constituted misdemeanors' reversed and remanded with directions to enter judgment for the defendants.
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