SW Legal studies in Business

Drunk Driver Killed in Accident Not Due Personal Accident Insurance Benefits
Description Appeals court held that a drunk driver who was killed in a one-car accident violated the terms of his Personal Accident Insurance policy as the cause of death was self-inflicted due to voluntary consumption of a large amount of alcohol.
Topic Insurance
Key Words

Death Benefits; Personal Accident Insurance; Denial; Alcohol

C A S E   S U M M A R Y
Facts At 2:30 a.m. Lennon drove his car into a wall and died. His blood alcohol was estimated to be 0.32, more than triple the legal limit. MetLife provided insurance benefits for Lennon via his employer, GM. It paid his life insurance benefits to his mother but refused to pay Personal Accident Insurance benefits. Such benefits are for “accidental bodily injuries” or death. The policy excluded benefits in case of “suicide … or self-inflicted injury while sane or insane.” MetLife contended that voluntary heavy drinking impaired Lennon’s driving and he should have foreseen the possible consequences, so this was an intentional self-infliction of injuries. Lennon’s mother sued for payment of those benefits. The district court held that death was caused by an accident and the benefits should be paid. MetLife appealed.

Reversed. The denial of benefits was not arbitrary and capricious. High blood-alcohol levels substantially increase the risk of being in a fatal accident. Lennon was driving at a high rate of speed on a well-lit road and plowed into a wall. The accident would likely not have occurred had he not been drinking as no other factors appear to have contributed to the incident. Hence, his voluntary consumption of alcohol was a self-inflicted injury and the Personal Accident Insurance benefits need not be paid.

Citation Lennon v. Metropolitan Life Insurance Co., 504 F.3d 617 (6th Cir., 2007)

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