ERISA- Eighth Circuit Uphold District Court’s Decision That Death Was Accidental, So That A Death Benefit Is Payable

In Nichols v. UniCare Life and Health Insurance Company, Nos. 12-4047, 13-1033 (8th Cir. 2014), defendant UniCare was appealing the district court’s grant of summary judgment to the plaintiff Nichols. In this case, Nichols is the surviving spouse of Dana Nichols. Dana was employed by Acxiom Corporation, and she was insured under the Acxiom Corporation Life and Accidental Death and Dismemberment Insurance Plan (the “Plan”). The Plan is funded by a policy underwritten by UniCare, and UniCare also serves as the claims administrator.

On May 3, 2010, Dana was found face down in bed, and upon being transported to a nearby hospital, she was pronounced dead. The autopsy report indicated that her manner of death (natural, accidental, etc.) “could not be determined,” and her cause of death was mixed drug intoxication. Nichols filed a claim for accidental death benefits under the Plan. UniCare-as claims administrator- ultimately denied Nichols’ claim, on the grounds that: (1) the manner of death was listed on the death certificate as “could not be determined,” and (2) the Plan excludes benefits for death caused by intoxication. This suit ensued. The district court, applying a de novo standard of review, granted Nichols the accidental death benefits in a summary judgment, finding that the cause of Dana’s death was more likely than not an accident and rejecting the argument that Dana’s consumption of numerous medications was an intentional act so that no accident had occurred. UniCare appeals.

In analyzing the case, the Eighth Circuit Court of Appeals (the “Court”) agreed with the district court, which had said that, in sum, all of the evidence indicates that Dana’s death was the unexpected result of ingesting prescribed medications. That is, the death was an accident. Accordingly, the Court concluded that the district court correctly found that UniCare erred in denying coverage for accidental death benefits. The Court also rejected an application of the Plan’s intoxication exclusion, since UniCare had not met its burden that this exclusion applied. As such, the Court affirmed the district court’s decision.

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