VARDIT M. SASLOE, APPELLANT,
v.
HOME LIFE INSURANCE COMPANY, NEW YORK, A FOREIGN CORPORATION, APPELLEE
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A beneficiary of a life insurance policy appeals a directed verdict in favor of the insurer, challenging the insurer's denial of an accidental death benefit based on policy exclusions for deaths resulting from drugs or medicines. The court affirmed the directed verdict, holding that the insured's death from a drug-impaired driving accident fell squarely within the policy's exclusion for deaths resulting from drugs.
The court held that because the evidence demonstrated the drugs ingested by the insured had a direct causal relationship with his death, or at least indirectly or partly contributed to it, the death fell within the policy's exclusion for drug-related deaths, and the insurer was not liable under the policy.
[1] An insurance policy exclusion for death resulting directly or indirectly, wholly or partly, from drugs applies when the insured's drug intoxication directly contributes t…
[2] Evidence of a lethal range of drugs in the insured's blood, coupled with testimony of erratic driving and the absence of mechanical failure, can establish a causal link b…
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Join FLexlaw to unlock all legal intelligence“The Company does not assume the risk ... if death results directly or indirectly, wholly or partly, from ... medicines; drugs; sedatives; ... [or] committing or attempting to commit a crime”
The relevant policy language that excluded coverage for drug-related deaths.
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Join FLexlaw to unlock all legal intelligenceMark Sasloe died when his automobile struck a tree while he was driving erratically and at excessive speed. An autopsy revealed Methaqualone in the le…
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BARKDULL, Judge.
The named beneficiary of an insurance policy, appeals a final judgment entered pursuant to a directed verdict, at the close of all the evidence, in favor of the insurance company.
Yardit Sasloe filed suit seeking to recover the $10,000 accidental death benefit on a life insurance policy issued to Mark Sasloe. The insurance company denied that the benefit was due because Mark’s death was the result of one or more specifically excluded risks. The policy provided, in part, that:
The Company does not assume the risk ... if death results directly or indirectly, wholly or partly, from . .. medicines; drugs; sedatives; ... [or] committing or attempting to commit a crime; ....
The evidence at trial revealed that Mark Sasloe, died when the automobile he was driving struck a tree in the median of the road. An autopsy was performed by Dr. Wright. The autopsy revealed a low-level of alcohol and the presence of Methaqua-lone in the “lethal range” in the blood; Valium, Phentermine, Quinine, Benzoyle-co-nine, aspirin and a trace of cocaine were in the urine. Dr. Wright opined that Mark was intoxicated with Methaqualone and that his intoxication directly contributed to his death in that it caused the collision.
Other witnesses testified that Mark was speeding and driving erratically just prior to and at the time of the accident. An investigating officer could find no mechanical failures in the vehicle which would have contributed to the accident.
The evidence at the conclusion of the case amply demonstrated that the amount and type of drugs ingested by Mark Sasloe had a direct causal relationship with his death, or at least indirectly or partly contributed to his death.
Therefore, there was no liability under this policy. See and compare: Haines v. Southern Life and Health Insurance Company, 363 So. 2d 175 (Fla. 4th DCA 1978); Stinchomb v. Mutual Life Insurance Company of New York, 305 So. 2d 84 (Fla. 2d DCA 1974).
The cases relied upon by the appellant, [Harris v. Carolina Life Insurance Company, 233 So. 2d 833 (Fla.1970); Mason v. Life and Casualty Ins. Co. of Tennessee, 41 So. 2d 153 (Fla.1949); Mason v. Life and Casualty Insurance Company of Tennessee, 41 So. 2d 155 (Fla.1949)] are readily distinguishable; the Mason cases involved different policy language. In the Harris case, the insured was a passenger so his intoxication was unrelated to his accident.
The trial court was eminently correct in granting the directed verdict. Provident Life & Accident Ins. Co. v. Eaton, 84 F. 2d 528 (4th Cir. 1936); Order of United Commercial Travelers v. Tripp, 63 F. 2d 37 (10th Cir. 1933); Flannagan v. Provident Life & Accident Ins. Co., 22 F. 2d 136 (4th Cir. 1927); Tyler v. American Home Assurance Corporation, 337 So. 2d 919 (La.App. 3rd Cir. 1976); Richard v. American Home Assurance Company, 318 So. 2d 613 (La.App. 3rd Cir. 1975); Young v. All American Assurance Company, 243 So. 2d 894 (La.App. 3d Cir. 1971); Matthews v. All American Assurance Company, 226 So. 2d 181 (La.App. 3d Cir. 1969).
Therefore, the final judgment is affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Buck v. Gulf Life Ins. Co., 548 So. 2d 715 (Fla. 4th DCA 1989)…of law, that materially contributed to the loss. See generally The Maccabees v. Terry, 67 So. 2d 193 (Fla.1953); Edwards v. Bankers Life and Casualty Co., 381 So. 2d 761 (Fla. 1st DCA 1980). See also Sasloe v. Home Life Insurance Company, New York, 416 So. 2d 867 (Fla. 3d DCA 1982). Appellee further asserts that no evidence was submitted by appellant establishing a genuine issue of fact. The appellant does not contend that there are disputed issues of fact to be resolved. Rather, appellant asserts that she…1 / 2
Authorities Cited
- Harris v. Carolina Life Ins. Co., 233 So. 2d 833 (Fla. 1970)
- Flannagan v. Provident Life & Accident Ins. Co., 22 F.2d 136 (4th Cir. 1927)
- Mason v. Life Cas. Ins. Co. of Tenn., 41 So. 2d 153 (Fla. 1949)
- Mason v. Life Cas. Ins. Co. of Tenn., 41 So.2d 155 (Fla. 1949)
- Provident Life & Accident Ins. Co. v. Eaton, 84 F.2d 528 (4th Cir. 1936)
- Stinchomb v. Mut. Life Ins. Co. of N.Y., 305 So. 2d 84 (Fla. 2d DCA 1974)
- Order of United Commercial Travelers of Am. v. Tripp, 63 F.2d 37 (10th Cir. 1933)
- Haines v. S. Life & Health Ins. Co., 363 So. 2d 175 (Fla. 4th DCA 1978)