In American Heritage Life Insurance Company v. Morales, the policyholder purchased an accidental death and dismemberment policy. The life insurance policy contained an exclusion applicable to “any loss incurred as a result of . . . any injury sustained while under the influence of alcohol or any narcotic unless administered upon the advice of a physician.” The insured was fatally injured in a jet ski accident that occurred in Biscayne Bay in Miami. When the beneficiaries of the policy submitted a claim for benefits under the life insurance policy, the insurer denied the claim based on the alcohol exclusion provision.
The policyholder was last seen prior to death as he departed an island north of the Venetian Causeway in the Intracoastal Waterway. After the policyholder’s body was discovered, an autopsy concluded that the cause of death was attributable to blunt force trauma experienced in a frontal impact collision with a stationary object. A blood test indicated that the insured’s blood alcohol concentration (BAC) was .10, which exceeds the legal limit under Florida law.
The expert that testified for the beneficiary at trial conceded that the insured was violating Florida’s boating under the influence (BUI) law at the time of the crash. However, the expert also testified that other causes contributed to the fatal accident, such as: (1) poor lighting; (2) the insured’s failure to keep a proper lookout; and (3) the policyholder’s operation of the watercraft in a negligent /reckless manner. The opinion expressed by the expert indicated that because a range of factors all contributed to the crash, characterization of alcohol as the “cause” of the boat crash amounted to “pure speculation.”
The trial court sided with the insured and ordered the insurance company to pay the benefits articulated in the policy. The insurance carrier appealed. The appellate court reversed based on the rationale that there was no dispute that alcohol was a factor in causing the crash. A causal connection was established between intoxication and the death even though alcohol was not the exclusive factor in causing the death according to the court.
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