Employee Benefits Law—Drunk Driving Fatality Determined Not Accidental Under ERISA-Governed Insurance Plan—Stamp v. Metropolitan Life Insurance Company, 531 F.3d 84 (1st Cir. 2008)

Federal common law governs claims arising out of employee benefit plans covered by the Employee Retirement Income Security Act of 1974 (ERISA).  The Court of Appeals for the First Circuit created an approach for interpreting the ambiguous word “accident” in ERISA-governed plans in Wickman v. Northwestern National Insurance Co.  In Stamp v. Metropolitan Life Insurance Co., the First Circuit used the Wickman framework to address, for the first time, whether the administrator of an ERISA-governed plan could reasonably conclude that the death of an insured party who was killed in a single-car accident when driving drunk was not accidental for purposes of his life insurance policies.  The First Circuit reviewed the administrator’s decision under an arbitrary and capricious standard and upheld the decision as both reasonable and supported by the evidence on the record. . . .