In Gianfranco Arena v. RiverSource Life Insurance Co., the United States Third Circuit Court of Appeals addressed a case in which the Plaintiff brought suit against an insurer after theinsurer denied the insured’s claim for life insurance due to a suicide exclusion clause in the policy. The District Court had granted the insurer summary judgment after determining that the actions the decedent took to cause her death were sufficient circumstantial evidence to establish that she intended to end her life. The Court held that the insurer showed that the coverage exclusion applied and that the insured failed to produce evidence demonstrating a genuine issue of fact that could defeat summary judgment. The Appeals Court affirmed the judgment of the District Court in all respects.
This case arose when the decedent purchased two life insurance policies in 2014. Both policies contained “suicide exclusion” clauses that limited the insurer’s liability for death by suicide. The policies provided that “[i]f the insured, whether sane or insane, dies by suicide within 2 years from the Policy Date, [the insurer’s] liability is limited to an amount equal to the total premium payments.” In 2015, the decedent fell onto some financial troubles that took a mental toll on her and she sought the aid of a psychologist to address some issues. The decedent was prescribed anti-depressants. On April 21, 2015, the decedent used her husband’s belt and attempted suicide by hanging. Family members found her still alive and she was taken to the hospital, where she passed away nine days later. Themedical examiner listed the decedent’s manner of death as a suicide.
The decedent’s husband attempted to file a claim for life insurance benefits; however, the insurer denied the claim on the basis of the death certificate and the exclusion clause in her policy. The decedent’s husband asked the insurer to reconsider its decision, and argued that the decedent’s death was a result of the medication she was prescribed, but the insurer reaffirmed its decision. The decedent’s husband then filed a breach of contract claim in the Superior Court of New Jersey, which was promptly removed to the District Court.
On appeal, the insured argued that that the decedent would not have committed suicide but for the effect that the prescription medications had on her state of mind. According to the insured, the medication caused a mental disorder so extreme that the decedent could not comprehend her actions. In support of its argument, the insured put forward testimonial evidence from friends, family, and colleagues, who stated that the decedent never would have committed suicide if she had been thinking clearly. There was also evidence put forward from doctors who claimed that in their expert opinions, the decedent suffered from “medication-induced suicidality.”
The Court looked to the case of Johnson v. Metropolitan Life Insurance Co., which established that killing oneself does not always qualify as suicide and that intent to do so is required. TheJohnson Court specifically identified two situations in which the deceased would not have the required intent to commit suicide. The first is a circumstance where a purposeful action is taken but the result is not intended. The second is when a person’s “mental disorder [is] . . . so extreme that he has no comprehension of what he is doing.” The Johnson opinion also held that intent can be inferred from a decedent taking actions that will result in death. The insured argued that the mental state of the decedent fell under the “no intent” situation in Johnson.
Applying the Johnson decision to the instant case, the Court found that the actions the decedent took constituted sufficient circumstantial evidence to establish an “awareness” that her actions would end her life and that she had an intent to do so. The Court found the evidence presented by the insuredunpersuasive because this evidence did not undermine the undisputed facts showing that the decedent took deliberate acts to commit suicide. The Court determined that the evidence only showed that while she may have acted under an irresistible impulse caused by the medication, an irresistible impulse does not demonstrate that the person lacked intent or had no comprehension of their actions. The Court, quoting Johnson,found that such an impulse would “’affirmatively establish that self-destruction was the very result intended, albeit by a deranged mind.” As the Court held that the decedent had the requisite intent to commit suicide, it affirmed that District’s Court’s decision to grant summary judgement to the insurer.
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