Brown v. Stonebridge Life Insurance Co.

Citations: 2013 IL App (3d) 120295; 990 N.E.2d 895Docket: 3-12-0295

Court: Appellate Court of Illinois; May 30, 2013; Illinois; State Appellate Court

Original Court Document: View Document

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Defendants Stonebridge Life Insurance Co. and Monumental Life Insurance Co. were not obligated to pay accidental death benefits to plaintiffs Thomas W. Brown, Jr. and Dawn Balicki, as their mother Margaret Jane Brown's death resulted from accidental fentanyl intoxication during medical treatment, which was explicitly excluded by the medical treatment exclusion in both insurance policies. The Circuit Court of La Salle County granted summary judgment in favor of the defendants after determining that Brown's death was linked to her ongoing medical treatment for chronic low back pain, thus dismissing the case with prejudice. The appellate court affirmed this decision, noting that the policies provided by both insurers clearly outlined terms, conditions, and exclusions that applied to the circumstances of Brown's death. Brown had enrolled in the Monumental Life insurance plan on June 4, 2002, and later applied for coverage with Stonebridge Life on February 24, 2004, naming her children as beneficiaries. She had a documented history of chronic pain and had been prescribed a fentanyl patch, which was administered over a period leading up to her death on December 20, 2007.

On December 20, 2007, Brown died from accidental fentanyl intoxication, as indicated on her death certificate. An autopsy revealed she had two fentanyl patches on her back, one delivering 100 micrograms per hour and another 25 micrograms per hour. Dr. Estilo testified that Brown showed no signs of fentanyl intoxication during an examination on October 18, 2007, and there was no evidence of misuse of the patches. In April 2008, the plaintiffs submitted claims for accidental death benefits to Monumental Life and Stonebridge Life. Both companies rejected the claims on June 24, 2008, citing policy exclusions related to sickness and medical treatment, referencing that Brown’s fentanyl concentration of 9.7 ng/mL exceeded her physician's prescription.

On June 4, 2009, the plaintiffs filed a complaint for declaratory judgment against Stonebridge Life in La Salle County circuit court, seeking $25,000 in benefits. They later amended the complaint on June 22, 2010, to include claims against both insurance companies. The Stonebridge policy stipulates that a "loss" includes death, with specific definitions for "injury" requiring it to be caused by an accident while the policy is active. Exclusions include injuries related to narcotics unless prescribed, and those resulting from sickness or medical treatment. Similarly, the Monumental Life policy defines "loss" to include the insured's death and specifies that injuries must be accidental, not caused by sickness or drugs unless prescribed.

On November 17, 2011, Stonebridge Life and Monumental Life filed motions for summary judgment against the second amended complaint, asserting that the undisputed facts indicated Brown had chronic back issues and died from fentanyl intoxication following a prescription for the narcotic. Both defendants argued that the policy treatment exclusions applied, warranting dismissal of the complaint with prejudice. 

In response on January 10, 2012, plaintiffs acknowledged several undisputed facts: Brown's death was due to prescribed fentanyl; she was treated for chronic lower back pain; and her physician, Dr. Estilo, had prescribed fentanyl as part of her pain management plan. The plaintiffs contended that the circumstances of Brown's death were accidental and unintentional due to the prescribed use of fentanyl.

Regarding the Stonebridge Life policy, plaintiffs pointed out two conflicting exclusions: one exclusion for death resulting from medical treatment and another for death while using narcotics unless prescribed. They argued that the policy's language allowed for coverage when a drug was taken as prescribed, asserting that since Brown had a prescription, coverage should apply.

Similarly, the plaintiffs highlighted ambiguities in the Monumental Life policy, which also included exclusions for losses due to sickness or medical treatment and for drug use unless prescribed. They maintained that, under both policies, since Brown may have used the fentanyl correctly as prescribed, the exclusions should not apply, and accidental death benefits should be awarded.

During a hearing on March 15, 2012, the court found that the facts supported the conclusion of accidental ingestion of fentanyl. It determined that ambiguities in the insurance contracts must be interpreted in favor of the insured, given the context of the agreements between a layperson and an insurance company.

The court determined that the insurance policies in question contained clear exclusions, specifically regarding narcotics or drugs not prescribed by a physician. It ruled that since Brown was taking a prescribed drug, this exclusion did not apply to her case. Consequently, the only relevant exclusion pertained to medical treatment, which led to the court granting summary judgment for the defendants, as Brown's death was deemed to be a result of ongoing medical treatment excluded from coverage.

The plaintiff appealed, arguing that the trial court made an error by granting summary judgments, asserting that the policies contained ambiguities and contradictory exclusion clauses that should favor the plaintiffs. The defendants contended that the policies were unambiguous and excluded coverage for Brown's death resulting from medical treatment.

The appellate court's review of the summary judgment is de novo, and it must assess whether the exclusion clauses in the policies create ambiguity concerning ongoing medical treatment involving prescribed narcotics. The court emphasized that ambiguity is determined by whether the policy language allows for multiple reasonable interpretations. 

The plaintiffs argued that the drug exclusion implies coverage for individuals taking prescribed medications at the time of accidental death and claimed that this creates inconsistency with the medical treatment exclusion. They maintain that a comprehensive reading of the policies reveals ambiguity regarding coverage for accidental deaths involving prescribed narcotics.

Each insurance policy explicitly excludes coverage for death or injury resulting from the use of non-prescribed drugs or narcotics. The interpretation of this exclusion indicates that injuries from illegal drugs or misuse of prescribed controlled substances are not covered. This exclusion aligns with a separate provision concerning accidental death from prescribed narcotics used in medical treatment, which stands independently and does not conflict with the drug exclusion. In this case, it is undisputed that the insured, Brown, was under medical treatment involving prescribed fentanyl for chronic pain at the time of her death. Therefore, the accidental death due to fentanyl intoxication falls within the clear limitations set by the policy language. The circuit court's decision to grant summary judgment in favor of the defendants, Stonebridge Life and Monumental Life, is affirmed.