Williams v. Unum Life Insurance Company of America, No. 20-1694 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit held that an accidental death and dismemberment insurance policy does not qualify as a health plan under Maine law, Me. Rev. Stat. Ann. tit. 24-A, 4303. Therefore, Unum Life's decision to deny benefits is subject to a deferential abuse of discretion standard of review. In this case, substantial evidence supported Unum Life's conclusion that intoxication contributed to the insured's fall down the stairs, which resulted in her death. The court concluded the Unum Life did not abuse its discretion in denying benefits under the policy's intoxication exclusion.
Court Description: [Stras, Author, with Smith, Chief Judge, and Arnold, Circuit Judge] Civil case - Insurance. The accidental-death-and-dismemberment insurance policy did not qualify as a health plan under Maine law, and the defendant insurer's decision to deny benefits was subject to the abuse-of-discretion standard of review; the district court properly applied this standard and did not err in determining that the insurer did not abuse its discretion in denying plaintiff's claim for benefits.
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