Eleventh Circuit Hands Win to Reliance Standard in Dispute over Accidental Death Insurance Benefits Where Body Was Never Found

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At the time of his death, Dr. Goldfarb was enrolled in his employer’s employee benefits plan, which included basic life and AD&D benefits insured by Reliance Standard. Dr. Goldfarb had the max benefit of $500,000 under each policy. Reliance Standard paid the basic life benefit. To qualify for AD&D benefits for loss of life resulting from an “injury,” the loss must be “caused solely by an accident.” The policy did not define accident but defined “injury” as “accidental bodily injury to an Insured that is caused directly and independently of all other causes by accidental means,” without defining accidental or accidental means. Reliance Standard denied the beneficiaries’ claim for AD&D benefits because it was not certain that Dr. Goldfarb suffered loss of life caused solely by an accident given that his true cause of death was unknown.
 
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