Santos v. Minnesota Life Insurance Company

Background

This was an Employee Retirement Income Security Act (ERISA) case involving Minnesota Life’s group accidental-death policy for Apple employees. Samuel Chong was insured under the policy, and Eva Marie Santos, his cousin, sued as administrator of his estate. The policy provided a $311,000 accidental-death benefit. Minnesota Life had already paid the separate $311,000 basic life-insurance benefit.

Chong was found dead in his apartment. The autopsy identified blunt-force head trauma with a subdural hematoma consistent with a fall. Methamphetamine, amphetamine, and temazepam were found in his blood and urine. The autopsy and death certificate classified the death as an accident. Minnesota Life denied the accidental-death claim, reasoning that the methamphetamine contributed to the death and suggesting that the death resulted from an overdose. The parties agreed that the court would review the denial of benefits independently, without deference to Minnesota Life’s decision.

The policy covered death resulting directly and independently from an accidental injury. It excluded deaths caused directly or indirectly by being under the influence of a prescription drug, narcotic, or hallucinogen, unless the drug was prescribed and taken as directed.

Court’s analysis

The court reviewed the cross-motions under Federal Rule of Civil Procedure 52, which permits a court deciding a case without a jury to make factual findings and legal conclusions. Under the agreed de novo standard, the court independently evaluated whether Minnesota Life correctly denied benefits.

Whether the death was accidental

The court applied the Ninth Circuit’s test asking whether the death was unexpected or unintentional. Because the record did not show Chong’s subjective expectations, the court used an objective inquiry: whether a reasonable person with Chong’s background and characteristics would have viewed serious injury or death as substantially certain to result from his conduct.

The court found that the evidence showed an accident. The medical examiner classified the death as accidental, investigators found no evidence of an intentional overdose, suicide attempt, second party, or foul play, and the record did not show that Chong expected or foresaw falling in his apartment. The court concluded that Santos proved by a preponderance of the evidence that Chong’s death was accidental.

Whether the drug exclusion applied

The court concluded that Chong’s death was at least indirectly caused by being under the influence of methamphetamine. But it also concluded that Minnesota Life did not establish that methamphetamine fit the policy’s ordinary and popular meanings of “prescription drug,” “narcotic,” or “hallucinogen.”

The court rejected Minnesota Life’s argument that methamphetamine should be treated as a prescription drug because a related pharmaceutical product, Desoxyn, can be prescribed. The court also found that methamphetamine is ordinarily understood as a stimulant, not a narcotic or hallucinogen. The court therefore held that the drug exclusion did not apply.

Other rulings

The court granted requests for judicial notice of National Institutes of Health webpages. It denied the request to consider Winek’s Drug & Chemical Blood-Level Data 2001 because the source acknowledged that its values were not absolute and could reasonably be disputed; the chart was excluded.

Santos requested attorney’s fees, costs, and prejudgment interest. The court denied the attorney-fee request without prejudice because Santos had not filed the separate motion required by the federal and local rules. The court awarded prejudgment interest at the default rate specified in 28 U.S.C. § 1961 because Santos had not shown that a different rate was warranted.

Disposition

The court granted Santos’s motion for judgment and denied Minnesota Life’s motion for judgment.