Heimer v. Companion Life Insurance Co.
879 F.3d 172
| 6th Cir. | 2018Background
- In April 2013 Beau Darrell Heimer (insured) drank with friends and later collided with another rider on an off‑road motorbike, suffering >$197,333 in medical bills; his post‑crash BAC was 0.152.
- Heimer submitted a claim to his insurer, Companion Life, which denied benefits citing a plan exclusion for injuries resulting from a "Covered Person's illegal use of alcohol."
- Heimer exhausted administrative appeals and sued; the district court ruled the exclusion refers to illegal consumption of alcohol (e.g., underage drinking), not illegal post‑consumption conduct (e.g., operating a vehicle while intoxicated), and awarded benefits.
- Companion Life appealed; the Sixth Circuit reviews the plan de novo and interprets plan terms according to ordinary meaning.
- The majority held "use of alcohol" ordinarily means the act of consuming alcohol and contrasted that with explicit plan language elsewhere using "under the influence," construing any ambiguity against the drafter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the exclusion for injuries from an "illegal use of alcohol" covers injuries caused by operating a vehicle while intoxicated | Heimer: "use of alcohol" means the act of consuming alcohol; his consumption was legal and the exclusion does not apply | Companion Life: "use" should be read broadly to cover being "under the influence" and thus injuries caused while intoxicated are excluded | The court held the ordinary meaning of "use" is consuming alcohol, not post‑consumption conduct; exclusion does not bar Heimer's claim |
| Contract construction rule when plan language is ambiguous | Heimer: any ambiguity must be construed against the drafter (insurer) | Companion Life: plan language should be read to effect insurer's intent to exclude intoxication‑related injuries | Court: even if language were ambiguous, rule against drafter supports Heimer; affirm district court judgment |
Key Cases Cited
- Hoover v. Provident Life & Accident Ins. Co., 290 F.3d 801 (6th Cir. 2002) (standard of review for plan interpretation is de novo in this circuit)
- Perez v. Aetna Life Ins. Co., 150 F.3d 550 (6th Cir. 1998) (plan provisions interpreted by ordinary and popular sense)
- Gallo v. Moen Inc., 813 F.3d 265 (6th Cir. 2016) (differences in plan wording require different meanings)
- Cultrona v. Nationwide Life Ins. Co., 748 F.3d 698 (6th Cir. 2014) (example of exclusion phrased to cover being "under the influence")
- Regents of Univ. of Mich. v. Emps. of Agency Rent‑A‑Car Hosp. Ass’n, 122 F.3d 336 (6th Cir. 1997) (ambiguities in plan language construed against drafter)