In a 2-1 decision with a strongly worded dissenting opinion, the 1 st U.S. Circuit Court of Appeals decided that U.S. District Judge Ronald R. Lagueuxof the U.S. District Court for the District of Rhode Island properly ruled thatMetropolitan Life Insurance Co. was within its rights to deny accidental death benefits to Karen Stamp, Steven Stamp’s widow.
Relying on its 1990 decision in an accidental death case that provided a way to determine whether an incident was an “accident”, the appellate panel found that Steven Stamp’s death was not an “accident” because death or serious injury is a “highly likely” outcome of driving while severely intoxicated.
Steven Stamp died after his automobile went off the road and struck a tree. At the time of his death, Stamp’s blood alcohol level was 0.265%, more than three times the legal limit in Rhode Island.
Karen Stamp argued that it was unreasonable to conclude that her husband’s death was not an accident because statistical evidence shows that less than 2% of individuals who drive while intoxicated become fatalities.The majority said statistical evidence does not consider the degree of intoxication of the driver in question.
However, in his dissent, Circuit Judge Juan R. Torruella argued that the majority, along with several other federal courts, have misapplied the 1990 case by focusing too heavily on whether death or injury is “reasonably foreseeable.”
“Mr. Stamp’s death can be termed nothing other than an unfortunate accident,” Torruella contended. “The question is not, as the majority frames it, whether Mr. Stamp was severely intoxicated. The question is whether he intended to kill himself by becoming intoxicated and driving while in this condition. There is absolutely no evidence that Mr. Stamp had any such intentionâ€¦. Accepting that Mr. Stamp had a (blood alcohol level)above the legal limit and that he was in a one-car collision with no other evidence of why he veered off the road and hit a tree, it is fair to say that, at most, Mr. Stamp miscalculated and misjudged his ability to drive that fateful evening.”
As the beneficiary of Stamp’s life insurance policy through his employer, Exxon Mobil Chemical Co., Stamp’s widow filed a claim for benefits. Metropolitan Life Insurance Co., as the plan’s claims administrator, paid Stamp’s widow life insurance benefits but denied her benefits under the plan’s accidental death and dismemberment provisions.
The widow then filed an administrative appeal with ExxonMobil, which agreed with MetLife that Stamp’s death was not the result of an accident. Stamp’s widow then filed a lawsuit.
The opinion in Stamp v. Metropolitan Life Insurance Co., 1st Cir., No. 07-1061, 6/30/08, is here .