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Riddle v. Life Ins. Co. of N. Am.

Riddle v. Life Ins. Co. of N. Am.

United States District Court for the District of New Jersey

October 11, 2011, Decided; October 11, 2011, Filed

Civil Action No. 11-1034(FLW)

Opinion

WOLFSON, United States District Judge:

Presently before the Court are cross motions for summary judgment by Plaintiff Beatrice Ruth Riddle ("Plaintiff" or "Riddle") and Defendant Life Insurance of North America ("Defendant" or "LINA"). The instant motions arise out of a Complaint by Plaintiff alleging that Defendant improperly denied accidental death benefits to Plaintiff following the death of her son, Kenneth Riddle ("Mr. Riddle"), in a car crash. For the reasons that follow, the Court grants Defendant's motion for summary judgment and denies Plaintiff's motion for summary judgment.

I. FACTUAL BACKGROUND

Initially, the Court notes that the parties have submitted a Joint Statement of Undisputed Material Facts. Thus, the following facts are not contested.

On December 12, 2007, Kenneth Riddle ("Mr. Riddle") was 44 years old and was employed by Cablevision Systems, Inc. ("Cablevision"). Mr. Riddle was a  [*2] participant in the Cablevision Systems Corporation employee benefit plan governed by the Employee Retirement Income Security Act of 1974 ("ERISA"). As part of his benefits with Cablevision, Mr. Riddle obtained basic and supplemental Accidental Death and Dismemberment ("AD &D") insurance coverage under two separate policies — COA8777 and OK815667. Policy COA8777 provides coverage for a "covered loss" that "results, directly and independently of all other causes, from bodily Injury which is suffered in an Accident which occurs while the person is a Covered Person under the Policy." Policy COA877 defines "Accident" as "[a] sudden unforeseeable external event, which: (1) causes Injury to one or more Covered Persons; and (2) occurs while coverage is in effect for the Covered Person." This policy provides a benefit of $195,000 for a covered loss.

Separately, Mr. Riddle received additional coverage under LINA Voluntary Personal Accident Insurance Group Policy OK8815667 which provides "benefits for loss from bodily injuries: (a) caused by an accident which happens while an insured is covered by this policy; and (b) which, directly and from no other causes, result in a covered loss." This Policy  [*3] provides a benefit of $250,000 for a covered loss. Unlike Policy COA877, however, Policy OK8815667 does not define the term "Accident." Under the terms of the Cablevision plan, LINA was the claims administrator for both policies.

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2011 U.S. Dist. LEXIS 117052 *; 2011 WL 4809037

BEATRICE RUTH RIDDLE, Plaintiff, v. LIFE INSURANCE COMPANY OF NORTH AMERICA, Defendant.

Notice: NOT FOR PUBLICATION

CORE TERMS

insured, driving, benefits, crash, summary judgment, coverage, accidental, reasonable person, speed, Policies, alcohol, blood, nonmoving, genuine, de novo review, nonaccidental, covered loss, speed limit, intoxicated, spectrum, drunk, wreck, accidental death benefit, accidental death, insurance policy, miles per hour, federal court, lose control, sudden, night

Civil Procedure, Summary Judgment, Entitlement as Matter of Law, General Overview, Judgments, Evidentiary Considerations, Genuine Disputes, Materiality of Facts, Opposing Materials, Accompanying Documentation, Burdens of Proof, Movant Persuasion & Proof, Nonmovant Persuasion & Proof, Scintilla Rule, Absence of Essential Element, Trials, Jury Trials, Province of Court & Jury, Pensions & Benefits Law, Judicial Review, Standards of Review, De Novo Standard of Review, Insurance Law, Life Insurance, Accidental Death, Handling of Claims, Scope of Review, Claim, Contract & Practice Issues, Policy Interpretation, Plain Language, ERISA, Federal & State Interrelationships, Federal Common Law, Applicability, Accident & Accidental Means Definitions, Reasonable Expectations, Commercial General Liability Insurance, Coverage