In Bond v. Ecolab, Inc., 2007 WL 551595 (E.D. Mich. Feb. 21, 2007, an ERISA plan participant died while engaging in autoerotic asphyxiation. The police and medical examiners concluded that the participant’s death was accidental. The plan’s claims administrator, MetLife, denied the beneficiary’s claim for benefits based on the plan’s exclusion for self-inflicted injuries. In entering judgment in favor of defendants, the district court rejected plaintiff’s argument that the death certificate’s identification of the manner of death as accidental was controlling and held that MetLife’s decision to deny benefits was not arbitrary and capricious because MetLife’s determination that the participant’s intentional disruption of oxygen to his brain was a self-inflicted injury and was not unreasonable in light of the plan’s language.

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This entry was posted by Adam V. Russo on Tuesday, July 28th, 2009 at 8:45 am and is filed under 6th, Exclusion, Plan Language. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.