Terri Yates v. Symetra Life Insurance Company, No. 22-2257 (8th Cir. 2023)
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After her husband died of a heroin overdose, Plaintiff sought accidental death benefits under an employer-sponsored benefit plan governed by the Employee Retirement Income Security Act of 1974 (ERISA). The plan’s insurer, Symetra Life Insurance Company, denied her claim, and Plaintiff sued. The district court granted summary judgment in Plaintiff’s favor. Symetra appealed, arguing that Plaintiff’s suit is barred by her failure to exhaust internal review procedures and that her husband’s death otherwise falls under an exclusion to coverage.
The Eighth Circuit affirmed. Symetra contends that the exclusion applies to Plaintiff’s husband’s death because he “purposely” used heroin. But just because the act of using an illegal substance is purposeful does not mean that an injury stemming from that act, including a fatal overdose, was too. Symetra also maintains that Plaintiff’s husband, as a “longtime drug user,” was surely aware of the risks of using heroin and that his “generalized knowledge” of such risks is sufficient for his death to fall under the “intentionally self-inflicted injury” exclusion. The court reasoned that even assuming Symetra’s characterization of Plaintiff’s husband’s drug use is accurate, the argument attempts to replace an exclusion that applies only to “intentionally self-inflicted” injuries with one that also includes injuries resulting from reckless, or even negligent, conduct. The court wrote that the plain language of Symetra’s “intentionally self-inflicted injury” exclusion does not apply to unintended injuries like Plaintiff’s husband’s heroin overdose. Thus, Symetra’s denial of Plaintiff’s claim for accidental death benefits based on that exclusion was erroneous.
Court Description: [Kelly, Author, with Shepherd and Grasz, Circuit Judges] Civil case - ERISA. Plaintiff's decedent died of a heroin overdose, and defendant. the plan administrator for the decedent's employer, refused to pay accidental death benefits, claiming the loss was caused by an intentionally self-inflicted injury and that such losses were excluded from coverage. The district court did not err in determining that the written Plan documents did not describe any appeal or review procedures plaintiff had to exhaust before brining suit; using heroin is not an intentionally self-inflicted injury and the overdose death was not an intended result of ingestion of the drug; the district court did not err in determining that the intentionally self-inflicted injury exclusion did not apply to unintended injuries, such as death by overdose.
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