Background
David Lennon died after his car left a well-lit boulevard and struck a wall. His blood-alcohol level was about 0.32, more than three times Michigan’s legal limit at the time. MetLife paid his basic and optional life insurance but denied the separate accident benefit. A federal district court ruled for his mother, finding he did not expect to die.
What the court held
The Sixth Circuit reversed. Because the plan gave MetLife discretion, the court asked only whether the denial was arbitrary and capricious. It held that MetLife could reasonably conclude that a death resulting from grossly negligent drunk driving is not an “accident,” even though the policy did not define the term to exclude such deaths.
Why it matters
Lennon shows how much the standard of review matters in AD&D claims (see Firestone). It does not mean every death involving alcohol is excluded. Results vary by circuit, facts, policy wording and whether review is deferential. Many policies now carry express intoxication or drug exclusions, which raise different questions.
Read the opinion
Lennon v. Metropolitan Life Ins. Co., 504 F.3d 617 (6th Cir. 2007), on the Sixth Circuit’s website. Related: Wickman v. Northwestern National.
Not legal advice. This page summarizes general rules and the specific statutes cited. Your policy's wording, the state whose law applies, and whether the coverage came through an employer can all change the result. See the disclaimer and editorial policy.