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Compliance December 7, 2005
Court Overturns Death Benefit Finding
December 7, 2005 (PLANSPONSOR.com) - A federal judge
in Michigan has agreed with an accidental death benefit plan
participant that the plan administrator acted unreasonably
when it refused to pay benefits for the participant's wife
who died in a car accident from driving while
intoxicated.
Reported by editors@plansponsor.com
US District Judge David Lawson of the US District Court for the Eastern District of Michigan said the administrator wrongly interpreted a “self-inflicted injuries” plan exclusion to include risky behavior such as drunk driving. There was no evidence that the dead woman set out to injure herself, Lawson ruled.
According to the court opinion, Michael Harrell’s wife, Terri, was killed in a 2003 car crash. On the way home from getting gas for her car, she veered across the center line and struck another car, spun out of control, and hit a telephone pole. A police laboratory report confirmed that her blood alcohol level was above Michigan’s legal limit.
As a General Motors Corp. employee, Michael Harrell was a participant in a life insurance plan that covered his wife. The plan was insured by Metropolitan Life Insurance Co. and governed by the Employee Retirement Income Security Act (ERISA). The plan provided for two types of insurance: dependent group life insurance and personal accident insurance. In September 2003, Harrell filed claims for both types of benefits. Harrell received $100,000 in benefits for life insurance benefits but was denied accident benefits.
MetLife asserted that Harrell was ineligible for accident benefit because of a plan exclusion for “self-inflicted injuries.” MetLife argued that Terri Harrell’s death was a result of her own intoxication and impaired judgment, the court said. Responding to MetLife, Harrell said his wife drank regularly and had a high tolerance for alcohol, the court said. Harrell said that on the night she was killed, she did not look drunk and that nothing unusual happened before the accident, the court said.
Lawson rejected MetLife’s interpretation of the plan in so far as it equated engaging in risky behavior with intending to injure one’s self. The court said that to condone such a construction would violate a rule of interpretation of ERISA plans by focusing on the expectations and intentions of the insured. Lawson said drunk driving deaths constitute less than one percent of the number of people arrested for drunk driving, and thus the statistics do not show the inevitability of death flowing from drunk driving.
The opinion in Harrell v. Metropolitan Life Insurance Co., E.D. Mich., No. 04-10072, 1/29/05, can be found here .
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