Nichols v. Unicare Life & Health Insurance, 739 F.3d 1176

Dana Nichols died May 3, 2010; death manner listed as undetermined with mixed drug intoxication in autopsy.
Plan insured Dana under Acxiom Corporation Life and AD&D Plan; UniCare is insurer and claims administrator.
Claim denied as accident benefits on grounds death was undetermined and intoxication exclusion may apply.
Nichols supplemented administrative record with medical/prescription records and family letters.
District court granted summary judgment for Nichols, applying de novo review; UniCare appeals.
Court holds abuse-of-discretion standard governs; intoxication exclusion does not bar entitlement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Discretionary authority and standard of review	Nichols: no discretion to UniCare; abuse review not warranted	UniCare: plan grants discretion under Ferrari	Abuse-of-discretion applies; district court correct
Accidental death determination under Wickman	Evidence supports accident as the unexpected result of medication	Wickman requires subjective expectation of harm; limited evidence	Nichols entitled to accidental death benefits under Wickman
Intoxication exclusion applicability	Exclusion not triggered; death caused by ingestion of prescribed meds	Exclusion covers death from intoxication	Exclusion not applicable; coverage denied

Wickman v. Northwestern National Insurance Co., 908 F.2d 1077 (1st Cir. 1990) (framework to determine if death was accidental from insured's perspective)
Ferrari v. Teachers Insurance and Annuity Ass'n, 278 F.3d 801 (8th Cir. 2002) (discretion to determine eligibility can be found in plan language)
Sheehan v. Guardian Life Insurance Co., 372 F.3d 962 (8th Cir. 2004) (intoxication exclusion interpreted to apply to driving, not ingestion of prescription drugs)
Farley v. Benefit Trust Life Ins. Co., 979 F.2d 653 (8th Cir. 1992) (burden on insurer to prove exclusion applies)