Court: Death by Heart Attack in Car Accident Means No Death Benefits

November 30, 2004 ( - A federal appeals court has ruled that an insured's death from a heart attack at the time of a car accident was not a direct result of the accident so the man's spouse is not eligible for death benefits.

>The 11 th  Circuit Court of Appeals, in the case of Dixon v. Life Insurance Company of North America (LINA), handed down a ruling that confirmed a lower court’s judgment on November 29.

>The case revolves around the death of Horace Dixon, who was an employee of CSX Corporation before he flipped his car after running off a road. Bystanders could twice find no pulse, and he was ruled dead at a hospital. A coroner identified the immediate cause of death as heart failure, with the accident as only a contributing factor. Further investigation showed that Dixon had died from cardiac arrhythmia due to heart disease. There were no signs of external injury on his body.

>Following her husband’s death, Annie Dixon filed for accidental death benefits from LINA, the underwriter of CSXs insurance plan. LINA denied the claim, since the plan stated that benefits will be paid out only when an accident is the only cause of death. Since Dixon died from heart failure, the accident could not ruled to be the only cause, LINA asserted. Dixon took the case to Georgia state court, and it was then moved to federal court for a summary judgment, which supported LINAs assertions that it should not distribute accidental death benefits in this case. Dixon then appealed to the 11 th Circuit.

>In his ruling supporting LINAs claim, Circuit Judge Hugh Cox, writing for the majority, stated that “the issue of whether, and to what extent, language in an ERISA policy may preclude recovery for accidental injury where some preexisting condition was a contributing factor is one of first impression in this circuit.” The court worried that an overly strict opinion of the plan wording would cause benefits to be paid out only when a participant died in perfect health.

“We therefore adopt the ‘substantially contributed’ test as the federal common law of this circuit,” Cox wrote. “Thus, we will not consider Mr. Dixon’s preexisting heart disease as a cause unless it substantially contributed to his death. Mr. Dixon suffered no external physical injuries from the auto accident. [Ms. Dixon’s] position is simply that the shock and fright of being run off the road by a speeding car triggered Mr. Dixon’s heart attack. But, the undisputed evidence shows that Mr. Dixon’s heart failure was directly due to his hypertensive heart disease. It is thus not disputed, on the record, that Mr. Dixon’s preexisting heart condition ‘substantially contributed’ to his death, regardless of whether the auto accident was the immediate cause in that it triggered his heart attack.”

>The 11 th Circuit’s decision is available here .