Bolin v. Hartford Life & Accident Insurance, 28 F. Supp. 3d 915

Davidson suffered from back spasms, degenerative disc disease, post-laminectomy syndrome, arthritis, and tremors, treated with hydrocodone-acetaminophen, oxycodone, and benzodiazepine.
Davidson died after ingesting alcohol while taking prescribed pain medications; autopsy found mixed drug toxicity and a blood-alcohol level of .318.
Hartford Life and Accident Insurance Company issued a $100,000 accidental-death-and-dismemberment policy to Davidson; the policy excludes sickness or medical treatment as a cause of death.
Bolin (Davidson’s mother) and Pamela Miller (his sister) were designated beneficiaries and filed a claim for accidental-death benefits, which Hartford denied.
The parties filed cross-motions for summary judgment in federal court; the court applied Minnesota law and granted Hartford’s motion, denying Bolin and Miller’s claim.
The court held that Davidson’s death did not result from an Injury under the policy because it resulted from medical treatment during which alcohol was consumed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether death falls within Injury under the policy’s exclusion	Bolin argues death resulted from Injury since alcohol use was not tied to medical treatment	Hartford argues death resulted from medical treatment, excluding it from Injury	Death did not fall under Injury; exclusion applies
Whether the death was caused by the medical treatment sufficiently to be excluded	There is a causal link but not necessarily proximate to medical treatment	Prescription-medication use after treatment caused death, aligning with exclusion	Death resulted from medical treatment, so not an Injury under the policy
Choice of law for applying the contract	Minnesota law should apply	Tennessee master policy location could apply Tennessee law	Minnesota law applied; no conflict with Tennessee law found; choice of law unnecessary to outcome
Applicability of concurrent/divisible-cause doctrine	Non-excluded cause (alcohol) could combine with excluded medical treatment	Doctrine requires non-excluded cause capable of causing injury independently	Divisible, concurrent-cause doctrine not applicable given lack of independent non-excluded cause

Peterson v. Fulton, 192 Minn. 360 (1934) (proximate cause framework for determining substantial factor in result)
Ross v. City of Minneapolis, 408 N.W.2d 910 (Minn. Ct. App. 1987) (interpretation of 'resulting from' language in policy context)
SECURA Supreme Ins. Co. v. M.S.M., 755 N.W.2d 320 (Minn. Ct. App. 2008) (policy exclusion applied where criminal-like conduct or related factors influence loss)