Insurance Claim – Coverage

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7^th Circuit Court of Appeals

Case Name: LeTran Tran v. Minnesota Life Insurance

Case No.: 18-1723

Officials: BAUER, MANION, and BRENNAN, Circuit Judges.

Focus: Insurance Claim – Coverage

Linno Llenos died engaging in an act known as autoerotic asphyxiation. His widow and beneficiary, LeTran Tran, filed a claim with Minnesota Life Insurance Company, seeking the proceeds from Llenos’s ERISA-governed life insurance policies. Minnesota Life paid most of her claims but denied coverage under Llenos’s Accidental Death & Dismemberment policy riders. Minnesota Life determined Llenos’s death was not accidental and fell under a policy exclusion for deaths resulting from “intentionally self-inflicted injury.” The district court reversed, ruling that Llenos’s death qualified as an accidental death and did not result from an intentionally self-inflicted injury.

Because a reasonable person would interpret Llenos’s cause of death, autoerotic asphyxiation, to be an “intentionally self-inflicted injury,” we reverse.

Reversed

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Derek A Hawkins is trademark corporate counsel for Harley-Davidson. Hawkins oversees the prosecution and maintenance of the Harley-Davidson’s international trademark portfolio in emerging markets.