993 F.3d 578
8th Cir.2021Background
- Eric Boyer died in a single-vehicle crash on January 22, 2016; his sister Amber is sole beneficiary under his Schneider Electric life and accident Plan funded and administered by Unum.
- The Plan covers "accidental bodily injury" but excludes losses "caused by, contributed to by, or resulting from . . . an attempt to commit or commission of a crime."
- Unum paid life insurance benefits but denied accidental death benefits, concluding Boyer’s speeding (~80 mph) and passing in a no-passing zone—as reported in the police report and five witness statements—were crimes that contributed to the crash.
- Amber appealed and sued under ERISA § 502(a)(1)(B); the district court granted summary judgment for Amber, finding Unum’s application of the crime exclusion unreasonable and unsupported by substantial evidence.
- The Eighth Circuit reviewed the denial for abuse of discretion (because Unum had discretionary authority) and reversed the district court, holding Unum’s factual finding and interpretation of "crime" were reasonable and supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Unum had substantial evidence that Boyer’s speeding/improper passing contributed to the crash | Unum lacked evidence of posted speed limit, Boyer’s speed, and causal contribution; icy roads and ME opinion undercut Unum | Police report and five eyewitness statements (including an off-duty sergeant), road markings, and officer notes support finding that speeding/passing contributed | Held: Substantial evidence supported Unum’s factual finding that Boyer’s illegal driving contributed to the crash |
| Whether the Plan’s "crime" exclusion reasonably includes Boyer’s conduct | "Crime" should not encompass ordinary traffic violations; exclusion is ambiguous and should not apply to speeding/passing | "Crime" reasonably includes acts punishable under law; dictionary definitions and Missouri classification of the offenses as misdemeanors support inclusion | Held: Unum’s interpretation was reasonable; speeding/improper passing could constitute a "crime" under the exclusion |
| Whether applying the exclusion frustrates the Plan’s accidental-death purpose or renders language meaningless | Including traffic offenses defeats the Plan’s goal and renders the exclusion overbroad | The Plan may limit benefits for losses contributed to by criminal conduct; exclusion does not preclude many non-criminal accidental deaths | Held: No conflict with Plan goals; exclusion reasonably narrows coverage without rendering the Plan meaningless |
| Whether Unum’s interpretation violates ERISA SPD disclosure requirements | SPD did not warn participants that traffic crimes would bar benefits, so participants lacked fair notice | The term "crime" inherently covers conduct criminalized by state law; SPD need not list every example | Held: No conflict with ERISA disclosure rules; ordinary meaning of "crime" provides fair notice |
Key Cases Cited
- Engle v. Land O’Lakes, Inc., 936 F.3d 853 (8th Cir. 2019) (standard of review for district-court review of ERISA benefit determinations)
- Mitchell v. Blue Cross Blue Shield of N.D., 953 F.3d 529 (8th Cir. 2020) (abuse-of-discretion review and substantial-evidence standard)
- Finley v. Special Agents Mut. Benefit Ass’n, Inc., 957 F.2d 617 (8th Cir. 1992) (factors for evaluating reasonableness of plan interpretation)
- King v. Hartford Life & Accident Ins. Co., 414 F.3d 994 (8th Cir. 2005) (courts should not replace a reasonable fiduciary interpretation)
- Metro. Life Ins. Co. v. Glenn, 554 U.S. 105 (2008) (conflict of interest may be considered but does not change abuse-of-discretion standard)
- Kutten v. Sun Life Assurance Co. of Can., 759 F.3d 942 (8th Cir. 2014) (reasonable interpretation aligns with ordinary/dictionary meaning)
- Wald v. Sw. Bell Corp. Customcare Med. Plan, 83 F.3d 1002 (8th Cir. 1996) (plans may limit benefits to preserve assets and exclude coverage for certain conduct)