Doris Meusy v. Montgomery Ward Life Insurance Company

Citations: 943 F.2d 1097; 91 Daily Journal DAR 10542; 91 Cal. Daily Op. Serv. 6901; 1991 U.S. App. LEXIS 19823; 1991 WL 163774Docket: 90-35762

Court: Court of Appeals for the Ninth Circuit; August 28, 1991; Federal Appellate Court

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Montgomery Ward Life Insurance Company appealed a district court ruling favoring Doris Meusy in her lawsuit for insurance benefits following her husband Merlin Meusy's death. The Ninth Circuit Court found that the lower court erroneously concluded Mr. Meusy's death, resulting from a self-inflicted gunshot wound, was proximately caused by a prior car accident, which lacked evidentiary support. The court criticized the reliance on the case Norbeck v. Mutual of Omaha Insurance Co. as misplaced. 

Merlin Meusy had suffered significant injuries from a car accident on September 2, 1983, leading to emotional distress, including feelings of shame regarding disfigurement. After a period of sobriety, he resumed drinking on December 2, 1983, culminating in a drunken state the following day. Following a conversation with his wife about personal struggles, he attempted suicide, which was initially interrupted but ultimately resulted in his death. Toxicology reports indicated a blood alcohol level of 0.21% at the time of death.

Mr. Meusy held an accidental death policy with Montgomery Ward, which defined "injury" to include bodily harm from accidents but excluded losses from self-inflicted injuries or suicide. His life insurance policy included a clause that limited benefits in the event of suicide within two years of the policy's inception. Mrs. Meusy's lawsuit followed the denial of her claim based on these exclusions, leading to a bench trial.

After reviewing testimonies from Mr. Meusy's family, toxicologists, the deputy coroner, and the prosecutor/coroner, the court determined that Mr. Meusy's death was proximately caused by injuries from a car accident on September 2, 1983. The court emphasized that the impact of the accident, which affected both Mr. Meusy's physical appearance and emotional state, continued to contribute to his death, regardless of his intoxication or mental state at the time of death. Consequently, Mrs. Meusy was awarded full benefits of $20,000 from the life insurance policy and $50,000 from the accidental death policy. Montgomery Ward appealed the decision, and jurisdiction was established under 28 U.S.C. 1291.

The standard of review for the district court's findings of fact follows the clearly erroneous standard, while legal interpretations are reviewed de novo. The district court chose not to rule on whether Mr. Meusy's death was a suicide, as its proximate cause determination was sufficient. It referenced the case of Norbeck v. Mutual of Omaha Insurance Co., where an accidental death award was upheld despite a self-inflicted gunshot wound, noting that the policy excluded suicide while sane or insane.

The court affirmed its obligation to adhere to the highest state court's rulings and intermediate appellate decisions in the absence of a state supreme court ruling. Although the Washington Supreme Court denied review of Norbeck, the court declined to question its validity as the cases differed factually. Unlike Norbeck, which had substantial medical evidence linking brain injury to the decedent's actions, the current case lacked such evidence, with no testimony indicating that the accident directly led to Mr. Meusy's suicide or exacerbated his mental health issues.

Mr. Meusy's serious disfigurement and subsequent depression following a car accident do not establish a causal link to an uncontrollable impulse for self-destruction, as previously recognized in the Norbeck case. Despite Mrs. Meusy's claims that Mr. Meusy's depression was significant, there is no evidence indicating it constituted an irresistible impulse. The case of Travelers' Ins. Co. v. Melick, which involved a different context of accidental injury leading to death, is not applicable here. 

At oral argument, Mrs. Meusy's counsel acknowledged that no Washington case supports recovery for suicide without medical evidence of causation. The district court's application of Norbeck was deemed a mistake, as the testimony did not substantiate a finding of causation linking Mr. Meusy's death to his car accident injuries. Furthermore, Mrs. Meusy's argument equating alcoholic intoxication with an uncontrollable impulse lacks support from the relevant cases and evidence. 

The evidence instead indicates that Mr. Meusy's death was a suicide, directly barring recovery under the suicide exclusions in the insurance policy. The appellate court reversed the district court's judgment, vacated the judgment against Montgomery Ward, and instructed to dismiss Mrs. Meusy's complaint, with each party bearing their own costs.