In denying the plaintiff’s motion for summary judgment, the court said MetLife’s denial of benefits was not arbitrary and capricious, but was reasonable based on the evidence it had, according to the opinion. With no eyewitnesses to the accident, the court said it was not unreasonable for MetLife to adopt the findings of investigators of the incident that caused the death of the plan participant’s husband.
US District Judge Barbara Crabb also said in the opinion that MetLife’s interpretation of the plan language used in the self-inflicted injury and intoxication exclusions was reasonable.
Angela Rekowski was an employee of Pfizer, Inc. and had enrolled her and her husband, Steven, into Pfizer’s life insurance and accidental death and dismemberment insurance plans. The accidental death and dismemberment plan had provisions stating that benefits will not be paid if it is determined that the death or accident is caused or contributed to by a self-inflicted injury or if the injured party is intoxicated at the time of the incident and is the operator of a vehicle involved in the incident.
During a trip with a friend, Mr. Rekowski’s body was found in his truck at the bottom of a lake next to the parking lot of the resort in which Rekowski and his friend stayed. According to the court document, after consuming alcohol at a tavern, Rekowski drove to the resort and let his friend out to check in while he parked his truck. Thirty-six hours later Rekowski’s body was found with his truck in park and the keys in the floor by the gas pedal.
An accident report filled out by the police said that the coroner believed Rekowski drove his truck into the lake, placed it in park, took the keys out and fell asleep. The death certificate listed his cause of death as drowning/freshwater and acute alcohol intoxication. His blood alcohol level, according to two toxicology reports was around .24, exceeding the state’s legal limit of .08.
Mrs. Rekowski submitted a claim for benefits under her life insurance and accidental death and dismemberment insurance plans. MetLife paid her the life insurance benefits, but denied her accidental death and dismemberment claim. In its denial, MetLife cited the plan’s self-inflicted injury and intoxication exclusions.
Mrs. Rekowski appealed the denial saying it was just as likely that her husband parked the truck, took the keys out of the ignition and fell asleep, and the weight of the truck caused it to roll down into the lake where he drowned.
The court ruled in favor of MetLife, saying Mrs. Rekowski’s theory of her husband’s cause of death was just as speculative as the investigators’ theory.
The opinion in Rekowski v. Metropolitan Life Insurance Co. is here .
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