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United States Court of Appeals for the Eighth Circuit
September 20, 2022, Submitted; February 23, 2023, Filed
No. 22-1093, No. 22-2257
KELLY, Circuit Judge.
After her husband died of a heroin overdose, Terri M. Yates sought accidental death benefits under an employer-sponsored benefit plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. §§ 1001-1461. The plan's insurer, Symetra Life Insurance Company, denied her claim, and Yates sued. The district court1 granted summary judgment in Yates's favor. Symetra now appeals, arguing [*2] that Yates's suit is barred by her failure to exhaust internal review procedures and that her husband's death otherwise falls under an exclusion to coverage. Having jurisdiction under 28 U.S.C. § 1291, we affirm.
At the time of her husband's death, Yates worked at Phelps County Bank and participated in the company's employee benefit plan (the Plan). Her husband was also covered under the Plan as a dependent. The Plan was issued and managed by Symetra and governed by ERISA. Its various benefits were summarized in an "Employee Benefits Insurance Certificate" issued to covered employees, and that Certificate included the policies and Plan language at issue in this case.2
Among the Plan's benefits was an "Employee Accidental Death and Dismemberment Insurance" policy, under which Symetra paid a "benefit amount" if a covered individual "suffer[ed]" certain losses, including a "[l]oss of life," due to "accidental bodily injury." ] A qualifying injury must have been "a sudden and unforeseen event, definite as to time and place." The policy also included seven exclusions to coverage, including one, as is relevant here, that excluded "any loss caused wholly or partly, directly or indirectly by . . . intentionally [*3] self-inflicted injury, whi[le] sane."
On December 20, 2016, Yates's husband was found dead in his bedroom. The parties do not dispute that he died of a heroin overdose. Yates subsequently filed a claim with Symetra for spousal life insurance and accidental death benefits under the Plan. Symetra awarded the former benefits but denied the latter. The company explained in a June 27, 2017 denial letter (the Denial Letter) that "in view of the fact that" Yates's husband's death was caused by his "intentional act of using [h]eroin," Yates was not entitled to accidental death benefits because losses caused by an "intentionally self-inflicted injury" were excluded from coverage.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
2023 U.S. App. LEXIS 4243 *; 60 F.4th 1109; 2023 WL 2174840
Terri M. Yates, Plaintiff - Appellee v. Symetra Life Insurance Company, Defendant - Appellant
Prior History: [*1] Appeal from United States District Court for the Eastern District of Missouri - St. Louis.
Yates v. Symetra Life Ins. Co., 578 F. Supp. 3d 1024, 2022 U.S. Dist. LEXIS 234, 2022 WL 19211 (E.D. Mo., Jan. 3, 2022)Yates v. Symetra Life Ins. Co., 2022 U.S. Dist. LEXIS 91956, 2022 WL 1618787 (E.D. Mo., May 23, 2022)
exhaust, documents, written plan, intentionally, self-inflicted, required to exhaust, administrative remedy, plan participant, benefits, heroin, internal review, accidental death benefit, district court, exhaustion of administrative remedies, employee benefit plan, review procedure, coverage, overdose, denial letter, denial-of-benefits, appeal procedure, contractual, claimant, remedies, denial of benefits, claim for benefits, plan administrator, summary judgment, regulations, motorcycle
Torts, Comparative Fault, Common Law Concepts, Sudden Emergencies, Civil Procedure, Justiciability, Exhaustion of Remedies, Administrative Remedies, Pensions & Benefits Law, Civil Litigation, Remedies, Exhaustion of Administrative Remedies, Causes of Action, Suits to Recover Plan Benefits, Appeals, Standards of Review, De Novo Review, Judicial Review, De Novo Standard of Review, Questions of Fact & Law, Administrative Law, Reviewability, Exhaustion of Remedies, Fiduciary Responsibilities, Plan Administration, Adherence to Plan, Disclosure, Notice & Reporting, Required Reports, Summary Plan Descriptions, ERISA, Reasonable Expectations, Business & Corporate Compliance, ERISA Pension Plan Qualification Requirements, Participation & Vesting, Participation Requirements