In a recent life insurance case, the court clarified the circumstances under which an intoxication exclusion in a life insurance policy applies to a decedent's cause of death. This case involved a widow whose claim for accidental death and dismemberment (AD&D) benefits was denied by the insurer, which cited an intoxication exclusion in the policy. When you need Louisiana interpleader lawsuit guidance simply call us.
The Incident
The decedent, a man who had been drinking heavily, fell off a pier and drowned. According to witnesses, he was seen carrying a forty-two-inch television to a boat docked near the pier. He later fell into the water, and his body was found approximately 20 feet from the pier in 15 to 20 feet of water. An autopsy confirmed that drowning was the sole cause of death. However, a toxicology test performed several hours after his death revealed a blood alcohol content (BAC) between 0.27 and 0.31 percent, which was three to four times the state’s legal limit for intoxication.
The Life Insurance Policy and Claim Denial
The decedent had a term life insurance policy issued by Colonial Life & Accident Insurance Company, which named his wife as the beneficiary. After the decedent’s death, the widow filed a claim for the $100,000 policy benefit. Colonial Life reviewed the case and agreed to pay the full death benefit but denied the claim for AD&D benefits, citing a policy exclusion for accidents that involve a blood alcohol level above the state’s legal limit for intoxication (0.08 percent).
The insurance company argued that the presumption of intoxication under state law applied because the decedent’s BAC was over the legal limit, and thus excluded him from receiving AD&D benefits.
The Court’s Ruling
The widow filed a lawsuit in state court against Colonial Life, but the insurer moved to have the case removed to U.S. District Court, claiming the claim was governed by ERISA. Both parties filed motions for summary judgment.
The court ruled in favor of Colonial Life, granting the insurer summary judgment. Colonial Life had argued that when a person’s BAC exceeds 0.08 percent, a legal presumption of intoxication arises, making them ineligible for benefits under the intoxication exclusion.
Intoxication and Legal Presumption
The widow contended that the intoxication presumption should only apply in cases involving driving or operating a vessel, not in the context of an accidental death. However, the court disagreed to some extent. While the presumption traditionally applied to driving, the court ruled that it should extend to any situation where the decedent’s negligence or irresponsible behavior contributed to the death, even if not related to operating a vehicle or vessel.
The court referenced cases from other states where driving under the influence laws were applied to situations outside of driving, emphasizing that the policy exclusion for alcohol-related accidents should cover deaths caused by irresponsible conduct related to intoxication, even if the decedent was not engaged in driving or boating.
Legal Implications
This case highlights how insurance companies can invoke intoxication exclusions in AD&D policies to deny claims when a decedent's actions—such as drinking—are deemed to have contributed to the fatal accident. The court’s ruling establishes that insurance companies can apply such exclusions based on state laws regarding intoxication, even if the accident did not directly involve driving or operating a vehicle.
If your life insurance claim is denied due to an intoxication exclusion or other policy clauses, consulting with an experienced life insurance attorney can help clarify your legal options. Our attorneys can assist you in challenging unfair denials and ensuring you receive the compensation your family deserves.