|Life Insurance Benefits Need Not Be Paid for Death of Drunk Driver|
Appeals court held that the administrator of a company’s employee benefits plan was within his rights to deny payment of life insurance benefits for an employee killed in a one-car crash when driving while highly intoxicated.
Life Insurance; Benefits; Drunk Driving
|C A S E S U M M A R Y|
Stamp attended a meeting for employees of Mobil in Connecticut. The meeting included dinner. After the meeting, he planned to drive to visit relatives some distance away. He had some drinks with dinner. On the way to his visit his relatives, he stopped at a bar. He died in a one-car accident when he drove off the road. His blood alcohol level was 0.265%, more than three times the legal limit, 0.08%. Police reported the road to be clear; the cause of the accident was being drunk. MetLife, which handled insurance benefits for Mobil employees, denied payment of Stamp’s Accidental Death and Dismemberment life insurance policy to his wife, contending that because he was voluntarily drunk the car crash was not an accident. Stamp’s wife sued. The district court held for MetLife. She appealed.
Affirmed. Under the Employee Reitrement Income Security Act (ERISA), the determination of plan benefits are upheld unless the administrator’s decision is arbitrary, capricious, or an abuse of discretion. That was not the case here. A reasonable person would have viewed death or serious injury as a likely outcome of driving with high blood alcohol content. At the level of alcohol Stamp had, all mental, physical and sensory functions were impaired, so the death is not the result of an accident.
|Citation||Stamp v. Metropolitan Life Insurance Co., 531 F.3d 84 (1st Cir., 2008)|
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