Administrator’s
Finding That Death While Driving While Intoxicated Was Not The Result Of An
Accident Was Not Arbitrary And Capricious
This case required the 1st Circuit to determine whether the administrator of an employee benefits plan governed by the Employees Retirement Income Security Act (“ERISA”), reasonably concluded that the insured, who was killed in a one-car collision with a tree while driving with a blood alcohol content of three times the legal limit, did not die as a result of an “accident” for purposes of his Accidental Death and Dismemberment life insurance policies. After careful review of the developing federal common law under ERISA, the circuit court upheld the plan administrator's determination that, in this case, the insured was so highly intoxicated that his death was not an “accident.”
Stamp v. Metropolitan
Life Ins. Co.
The 1st Circuit Court of Appeals’ jurisdiction includes Maine, Massachusetts, New Hampshire, Puerto Rico and Rhode Island.