Angela Johnson v. American United Life Insurance
716 F.3d 813
| 4th Cir. | 2013Background
- ERISA plan denied accidental death (AD&D) benefits for Richard Johnson's drunk-driving death; widow Angela Johnson seeks benefits.
- Richard had BAC 0.289 at time of fatal crash; crash occurred in SC while speeding; no initial alcohol report in police docs, but toxicology later confirmed intoxication.
- Policies: employer- and employee-paid AD&D policies issued by AUL; life benefits paid, AD&D benefits denied; Seat Belt Benefit exists only in employee-paid policy and has a drunk-driving limitation.
- Limitation language excludes many scenarios; Seat Belt Benefit expressly disallows payment when legally intoxicated; general AD&D limits apply too.
- District court applied NC statute defining accident (result language) and concluded Richard’s death was not accident; Fourth Circuit reviews de novo because no discretionary authority given to plan administrator.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Richard’s death qualifies as an accident under the plan | Johnson argues 'accident' is undefined and ambiguous; a reasonable person would view the death as accidental. | AUL contends death was the expected result of intoxicated driving; policy limitations and foreseeability preclude accident. | Accident ambiguity resolved in favor of insured; death deemed accidental. |
| What standard governs ERISA review of the benefit denial | ERISA de novo review applies; plan lacks discretionary authority to interpret terms. | Under Eckelberry framework, a deference-based approach may apply where definitions are vague. | De novo review governs; court independently determines eligibility. |
| Whether North Carolina § 58-3-30 is preempted by ERISA | NC statute defines 'accident' as 'result' language; saves law under ERISA's savings clause. | ERISA preempts state law; if not, analysis remains unchanged. | Preemption question not required for outcome; analysis yields same result. |
| Impact of conformity-with-state-laws clause on preemption | Clause shows intent to incorporate NC law, avoiding preemption concerns. | General clause does not moot ERISA preemption; still analyze under federal common law. | Conformity clause does not defeat ERISA preemption; outcome unchanged. |
Key Cases Cited
- Kovach v. Zurich American Insurance Co., 587 F.3d 323 (6th Cir. 2009) (insurer should clearly define 'accident' to avoid ambiguity)
- Wickman v. Northwestern National Insurance Co., 908 F.2d 1077 (1st Cir. 1990) (framework for interpreting undefined 'accident' as 'unforeseen' or 'unexpected')
- Eckelberry v. ReliaStar Life Insurance Co., 469 F.3d 340 (4th Cir. 2006) (definitional approach to 'accident' with foreseeability analysis; discretionary review issue)
- LaAsmar v. Phelps Dodge Corp. Life Acc. Death & Dismem. & Dep. Life Ins. Plan, 605 F.3d 789 (10th Cir. 2010) (ambiguity of undefined terms in ERISA plans; pro-insured interpretation favored)
- Gallagher v. Reliance Standard Life Ins. Co., 305 F.3d 264 (4th Cir. 2002) (interpretation of ERISA plans in insured's favor when ambiguity exists)