Dallas Fort Worth Insurance Lawyer Blog
Life insurance is an option, as far as this author knows, under all ERISA plans. Life insurance is treated virtually the same as other benefits under ERISA plans.
Here is a 2023, 19 page opinion from the United States Fifth Circuit Court of Appeals. The opinion is styled, Deepa Krishna v. Life Insurance Company of North America; Honeywell International, Incorporated Accidental Death and Dismemberment Plan; Honeywell International, Incorporated; Steven Jacobs; Honeywell International, Incorporated Benefit Plan.
This lawsuit is brought under the Employees Retirement Income Security Act of 1974, 29 U.S.C. Section 1001 et seq. (ERISA) after her husband Karthik died in the crash of a relatively small private airplane on which he was a passenger. Recovery was denied under ERISA because of an express exclusion of death or injury incurred as a passenger in such an aircraft. Summary judgment was eventually granted in the district court in favor of the defendants.
Looking at the legal standard involved the Court stated:
We review a district court’s summary judgment rulings de novo. Whether the district court employed the appropriate standard in reviewing an eligibility determination made by an ERISA plan administrator is a question of law. When an ERISA plan lawfully delegates discretionary authority to the plan administrator, a court reviewing the denial of a claim is limited to assessing whether the administrator abused that discretion. When a plan lacks a valid delegation clause, a denial of benefits challenged under Section 1132(a)(1)(B) must be reviewed under a de novo standard.
The court then applies the just stated law to the facts in the case and upheld the district court ruling.