Court Finds Reliance Standard’s Denial of Accidental Death Benefits Based on An Alcohol/Drug Exclusion Was Wrong
Before his death, Mr. Murchison was employed by Toyota. As part of his benefits package, Mr. Murchison elected to have accidental death and dismemberment insurance. If Mr. Murchinson suffered an accidental death, his beneficiaries would receive $597,000.
However, the policy also contained exclusions that would prevent the payment of benefits, even if his death was accidental. The relevant exclusions were:
- Any death in which the insured’s acute or chronic alcoholic intoxication is a contributing factor; or
- Any death in which the insured’s voluntary consumption of an illegal or controlled substance or a non-prescribed narcotic or drug is a contributing factor
Mr. Murchinson’s Death
Mr. Murchinson died on September 11, 2017. The records show that before his death he had been riding his ATV with friends and had been target practicing and drinking. Mr. Murchinson did not return home that night. He was eventually found dead wedged between a tree and his ATV.
The sheriff’s report ruled his death an accident. An autopsy revealed blunt force injuries as the cause of death. It also confirmed Mr. Murchinson had a high blood alcohol concentration.
Claim for Accidental Death Benefits
Following his death, Mr. Murchinson’s family (“Murchinsons”) filed a claim for accidental death benefits. Reliance Standard denied the claim stating that although his death was accidental, his death was contributed to by acute alcoholic intoxication and pain medications, and thus excluded.
The Murchinson’s appeared the denial of benefits. In support of the appeal, the Murchinson’s submitted the following:
- Sheriff’s report confirming that Mr. Murchinson died of multiple trauma and the manner of death was accidental
- Email between the Murchinson’s attorney and the Detective DeWayne Reynolds in which Mr. Reynolds stated he could not confirm whether alcohol or medication played a role into the ATV accident.
Reliance Standard denied the appeal. In doing so, Reliance again argued that alcohol and pain medication played a contributing factor in Mr. Murchinson’s death. Reliance also relied on the medical opinion of Dr. Matshes, a doctor hired to review the records. Dr. Mateshes made the following conclusions:
- Mr. Murchinson’s death could not be classified as a loss to which his acute or chronic alcoholic intoxication was a contributing factor.
- Mr. Murchinson’s death could not be classified as a loss to which the insured’s voluntary consumption of pain medication was a contributing factor.
- The consumption of alcohol or drugs may have been a risk factor for the circumstances that led to the accident, but it was impossible to say with certainty that alcohol or drugs played a role in the death.
The Court’s Review
To start, the court recognized Reliance Standard had the burden to prove that the exclusions applied. The court noted that the mere evidence of intoxication was not enough for the exclusion to apply, but instead there must be some evidence alcohol and/or medications had some effect to cause the accident.
Ultimately, the court held that Reliance Standard failed to meet its burden to prove the exclusions applied. The court cited the following reasons in support of its conclusion:
- There were no witnesses to the crash
- There was no evidence that Mr. Murchinson had committed a traffic violation
- The Sheriff’s report made no finding that alcohol or drugs contributed to the death
- The Autopsy listed blunt force injury to the neck as the cause of death
- Detective Reynolds could not confirm that alcohol or medication played a role in the accident
- Dr. Matashes’s opined that it was not reasonable to conclude that consumption of drugs and/or alcohol was a contributing factor in the death
In conclusion, the court found that there was simply insufficient evidence to tie alcohol or medications to Mr. Murchinson’s death. Thus, the Murchinson’s were awarded accidental death benefits.
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