Arnold v. Connecticut Mutual Life Insurance

95 Me. 331 (1901) · Supreme Judicial Court of Maine · June 26, 1901

Summary

In this Maine insurance dispute, the plaintiff sued on a life insurance policy after the insured committed suicide. The policy excluded coverage for self-destruction unless caused directly by disease or accident without voluntary act. The court upheld a jury verdict for the plaintiff, finding sufficient evidence that the insured's melancholia constituted insanity and that his suicide was its direct result, and rejecting the defense that alcohol use caused his condition.

Holdings

  1. The questions of insanity and causation were for the jury, and the verdict for the plaintiff was not manifestly wrong.
  2. The evidence did not show that the insured ever drank to excess or became intoxicated, and the jury was justified in finding for the plaintiff on this issue.

Questions Presented

  1. Whether the insured's suicide was the direct result of insanity such that the policy exclusion did not apply
  2. Whether the insured's insanity, if any, was caused by the occasional or habitual use of alcoholic stimulants

Disposition

other

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