v. New York Life Insurance Company
419 P.3d 576
Colo.2018Background
- Mark Renfandt obtained temporary life insurance from New York Life while his application was pending; policy excluded "suicide or intentionally self-inflicted injury . . . while sane or insane."
- About one month after issuance, Mark died from a self-inflicted gunshot; toxicology showed extreme intoxication (BAC 0.325%) and presence of benzodiazepine and marijuana.
- Wife (Melissa) claimed Mark was so intoxicated/sedated he lacked volition and suicidal intent and sued New York Life for breach of contract after the insurer denied benefits under the suicide exclusion.
- The federal district court found Colorado law unclear on whether a clause excluding "suicide, sane or insane" requires suicidal intent and certified the question to the Colorado Supreme Court.
- Colorado Supreme Court reviewed historical common-law and statutory context, prior Colorado precedent (Lockwood), and split authority nationally over whether "sane or insane" eliminates the intent requirement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does an exclusion for "suicide, sane or insane" bar recovery regardless of insured's intent/understanding? | Renfandt: exclusion does not apply because Mark lacked volition/intent due to intoxication; no "suicide." | New York Life: phrase "sane or insane" removes need to prove intent; any self-destruction is excluded. | The court held exclusion requires intentional self-destruction with intent to kill; "sane or insane" does not eliminate intent requirement. |
Key Cases Cited
- Lockwood v. Travelers Ins. Co., 498 P.2d 947 (Colo. 1972) ("suicide" requires both a voluntary act and suicidal intent in insurance context)
- Bigelow v. Berkshire Life Ins. Co., 93 U.S. 284 (U.S. 1876) (addition of "sane or insane" excludes those who intended self-destruction even if morally incapacitated)
- Mutual Life Ins. Co. v. Terry, 82 U.S. 580 (U.S. 1873) (interpreting "die by his own hand" to require capacity to understand moral character; court recognized insanity can negate suicide)
- Searle v. Allstate Life Ins. Co., 696 P.2d 1308 (Cal. 1985) ("suicide, sane or insane" requires suicidal intent; insanity does not automatically negate intent)
- De Gogorza v. Knickerbocker Life Ins. Co., 65 N.Y. 232 (N.Y. 1875) (majority view that "sane or insane" can bar recovery even for insane insureds who acted in a manner that would be suicide if sane)