Bethany Williams v. National Union Fire Ins., 792 F.3d 1136

Jack Williams, a named insured under his employer’s ERISA-governed accidental death policy, died from a pulmonary embolism caused by deep vein thrombosis (DVT) after ~28 hours of air travel over five days.
Policy Endorsement E-5 defines a covered “injury” as bodily injury that (1) directly results from an unintended, unanticipated accident that is external to the body, (2) occurs under a listed hazard, and (3) directly causes a covered loss independent of sickness, disease, or bodily infirmity.
Williams’s spouse submitted an accidental-death claim attributing death to DVT/PE; National Union denied benefits, concluding the death resulted from an internal sickness/disease process rather than an external accident.
Administrative appeal was denied; the beneficiary sued under 29 U.S.C. § 1132(a)(1)(B). Both parties moved for summary judgment in district court; the court ruled for the insurer.
The Ninth Circuit reviewed de novo (no discretionary grant to administrator) and affirmed: although the death was sudden and unexpected, it did not result from an unintended, unanticipated external event as required by Endorsement E-5.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams’s DVT/PE death was an “accident” under the policy (must be unintended, unanticipated, and external to the body)	Williams: prolonged, confined sitting on aircraft was an external cause and thus an accidental external event that directly caused death	National Union: the prolonged sitting was an ordinary, intended condition of travel and not an unexpected external occurrence; death resulted from an internal medical condition	Court: Held for National Union — death did not arise from an unintended/unanticipated external accident as required by the policy
Whether ordinary, foreseeable risks of travel (prolonged sitting) qualify as the required external accidental event	Williams: the chain of events began with an external condition (immobility in flight) so qualifies as external accident	National Union: the external condition was neither unexpected nor accidental; nothing unusual occurred during flights to make it an external accident	Court: Ordinary conditions of travel are not the kind of unexpected external occurrence required by the policy; no coverage

Lopez-Valenzuela v. Arpaio, 770 F.3d 772 (9th Cir.) (de novo review of summary judgment)
Metro. Life Ins. Co. v. Glenn, 554 U.S. 105 (U.S. 2008) (standard when administrator lacks discretionary authority)
Air France v. Saks, 470 U.S. 392 (U.S. 1985) (Article 17/Warsaw Convention: injury caused by an unexpected or unusual external event)
Rodriguez v. Ansett Austl. Ltd., 383 F.3d 914 (9th Cir.) (DVT death not ‘‘accidental’’ under Warsaw Convention principles)
Padfield v. AIG Life Ins. Co., 290 F.3d 1121 (9th Cir.) (ERISA policy terms interpreted in ordinary and popular sense)
Khatchatrian v. Continental Casualty Co., 332 F.3d 1227 (9th Cir.) (distinguishing accidental death from internal medical events)