Jay C. Richmond v. Life Insurance Company of North America

Summary

The Eighth Circuit affirmed denial of accidental death benefits under an ERISA plan, holding that the plan administrator reasonably interpreted the "voluntary ingestion" exclusion to include intravenous injection of unprescribed narcotics. Applying abuse-of-discretion review, the court found the administrator's interpretation consistent with the plan's language and context (including "gas or fumes") and supported by substantial evidence. The court did not reach whether the death was accidental because the exclusion was dispositive, and it also held that the administrator provided a full and fair review.

Holdings

1. LINA's interpretation of 'ingestion' to include absorption via intravenous injection was reasonable under the Finley factors.
2. LINA's application of the voluntary ingestion exclusion to Marie's death was supported by substantial evidence.
3. LINA provided Richmond with a full and fair review.

Questions Presented

1. Whether LINA's interpretation of 'ingestion' in the voluntary ingestion exclusion to include intravenous injection was reasonable.
2. Whether LINA's application of that interpretation to the facts was supported by substantial evidence.
3. Whether LINA provided Richmond with a full and fair review of his claim as required by 29 U.S.C. § 1133.

Disposition

affirmed