Accidental Death Insurance Policy – ERISA

Life insurance denials are much more common than people realize.  Most people would be of the opinion that once a person had paid for life insurance and then a death occurs, that the policy would pay.  That is not the case.

Here is an opinion from the Southern District of Texas, Houston Division.  It is styled, Sydney Joe Gray v. Minnesota Life Insurance Company.  This case involves an accidental death policy that is governed by the Employee Retirement Income Security Act of 1974 (ERISA).

The lawsuit is brought under 29 U.S.C., Section 1132(a)(1)(B).  The deceased, Michael Gray had an accidental death policy he obtained through his employment.  Sydney Gray is the beneficiary of the policy.

One extremely rare circumstance of this case is that there was actually a trial of the case.  ERISA cases are not trial to a jury, rather, they are only trials to the Judge.  The only evidence allowed at trial is the evidence that is in the administrative record.  This is two of the aspects about ERISA cases that are unique.

The Judge found in favor of Minnesota and this is a ruling regarding the attempt by Sydney to seek a different ruling pursuant to Federal Rule of Civil Procedure 52.

Under Federal Rule of Civil Procedure 59, “after a nonjury trial,the court may, on motion for a new trial, open the judgment if one has been entered, take additional testimony, amend findings of fact and conclusions of law or make new ones, and direct the entry of new judgment.”  The motion must be filed “no later than 28 days after entry of judgment.”  Courts do not grant new trials unless it is reasonably clear that prejudicial error has crept into the record or that substantial justice has not been done, and the burden of showing harmful error rests on the party seeking the new trial.

The purpose of motions to amend is to correct manifest errors of law or fact.  A party may move to amend the findings of fact even if the modified or additional findings in effect reverse the judgment.  A motion to amend, however, should not be used to introduce evidence that was available at trial but was not proffered, to relitigate old issues, to advance new theories, or to secure a rehearing on the merits.  Unless a motion to amend is based on newly discovered evidence, a trial court is only required to amend its findings of fact based on evidence contained in the record.  To do otherwise would defeat the compelling interest in the finality of litigation.

Sydney then argued his points but the Court rejected them.

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