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Cranfill v. Aetna Life Insurance Company4/9/2002
law jurisprudence. Second, in most ERISA cases, the federal courts must affirm the denial of benefits unless the decision to deny benefits was arbitrary and capricious. *fn6 We are not persuaded by the federal scheme. Instead, we are persuaded by the reasoning of other state courts which have overwhelmingly held that an insured's death, in circumstances similar to the circumstances of this case, is accidental and is not intentionally self-inflicted. *fn7
Separate and apart from the issue of whether Mr. Cranfill's death is covered as an accidental death is whether it is excluded as an intentionally self-inflicted injury. Again, we do not view the phrase as susceptible to two interpretations on its face and therefore we conclude the phrase is not ambiguous.
Aetna argues that an intentionally self-inflicted death is any death that is the natural and probable consequence of an intentional act. *fn8 Stated another way, Aetna's argument is that a court may infer an insured's intent to inflict his or her own death. We reject that notion. We are guided by our earlier decision in New York Life Ins. Co. v. Riggins, 1936 OK 528, 61 P.2d 543. In Riggins, the insured's surviving spouse sought insurance benefits for the death of her husband pursuant to two life insurance policies. The issue was whether the insured's chronic alcoholism was intentionally self-inflicted. We held it was not. We held that although the insured's act of consuming alcohol was intentional, his resulting brain damage from chronic alcoholism was not an intentional act of self-destruction. We held that the exclusion for intentionally self-inflicted injury applies only when then insured intended self-destruction, not when the insured "intentionally committed an act which unexpectedly results in death." Id. at 552.
Similarly in the instant case, we conclude that Mr. Cranfill's conduct of intentionally driving while intoxicated is not the equivalent of his intent or plan to cause his death. *fn9 A death is not intentionally self-inflicted for purposes of an accidental death policy merely because it resulted from engaging in negligent or even grossly negligent conduct, unless the insured intended to cause his own death. See Mid-Continent Life Ins. Co. v. Davis, 1935 OK 1019, 51 P.2d 319 Syllabus by the Court . To hold otherwise would be contrary to the expectations of Oklahoma insureds who have purchased accidental death insurance to protect their beneficiaries.
In sum, we answer the first certified question as follows. Under Oklahoma law, for purposes of an accidental death and dismemberment insurance policy, an insured's death is "accidental" and is not an "intentionally self-inflicted injury" in the context of the certified question.
II. PUBLIC POLICY
The second certified question concerns Oklahoma's public policy. Aetna suggests Oklahoma's public policy against driving while drinking necessarily implies a public policy against awarding accident insurance benefits for the death of an intoxicated driver in a single-vehicle wreck. Mrs. Cranfill suggests Oklahoma public policy favors the innocent beneficiary in this context.
Oklahoma undoubtedly has a longstanding and strong public policy against driving while drinking. See, e.g. 47 O.S. 2001 §761 (unlawful to operate motor vehicle while impaired by consumption of alcohol); 47 O.S. 2001 §11-902 (unlawful to operate motor vehicle while under the influence of alcohol). We do not believe, however, that denying accidental death benefits to Mrs. Cranfill in this context fosters the public policy against driving while drinking. Further, we find nothing in the Oklahoma statutes or case law relative to accident insurance that indicates the
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