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Sixth Circuit Allows Recovery For Accident After Use of Alcohol

Sometimes in Tennessee personal injury cases, a plaintiff will seek to recover damages from another individual who caused an injury or acted in a negligent manner that led to an injury. In other personal injury cases, an individual may be injured as a result of a simple accident, or an unforeseeable circumstance that another individual did not cause. In these cases, a plaintiff may seek to recover damages from an insurance provider, rather than another individual, in order to pay for medical expenses incurred as a result of the accident that occurred.

Under those circumstances, plaintiffs face the risk not that the defendant will deny liability but that the defendant, the insurance company, will refuse to pay based on some term of the insurance agreement. In a recent case before the Sixth Circuit, an insurance company did exactly that, seeking to deny coverage to a plaintiff based on a policy exception that the Sixth Circuit ultimately determined should not apply.

In this motorcycle accident case, B.H. was injured while riding motorbikes one night with friends. At the time, B.H. and his friends had been drinking, and during their ride B.H. ran into another of his friends. The injuries he suffered were severe, and B.H. accrued more than $200,000 in medical bills. At the time of the accident, B.H.’s alcohol limit was twice the legal limit, and he was charged with operating a motor vehicle over the legal limit. Shortly thereafter, B.H. filed a claim with his insurance company, Companion Life, for his injuries. The plan administrator denied his claim, stating that he fell within an exclusion that prohibited coverage for injuries resulting from the “illegal use of alcohol.” B.H. argued that his use of alcohol was not illegal at the time because he was over the age of 21. Instead, it was his use of a motor vehicle that was illegal. Companion Life disagreed.

The lower courts disagreed with Companion Life, finding that the plain meaning of “illegal use of alcohol” clearly meant that the use of alcohol was illegal, rather than that the actions that occurred after the consumption of alcohol were illegal. Companion Life appealed.

On appeal, the Sixth Circuit Court of Appeals considered what the ordinary meaning of “use of alcohol” was. Companion Life argued that it meant “to be under the influence of alcohol,” thus prohibiting illegal actions under the influence of alcohol, including B.H.’s motorcycle ride. The Sixth Circuit, however, disagreed. It found that the term clearly meant the action of partaking in something, or consuming something, and was not as broad as Companion Life had argued. Moreover, the Sixth Circuit also noted that different provisions of the plan specifically used the term “under the influence” when seeking to exclude actions that occurred under the influence of an intoxicant, and had the plan meant to apply the same definition to the illegal use of alcohol, it could have used those terms.

Finally, to the extent there was any ambiguity as to the term “illegal use of alcohol,” the Sixth Circuit concluded that the insurance plan should be construed against the drafter, and to provide protection to the claimant. Thus, here, even if B.H.’s plan was ambiguous as to whether it excluded claims for conduct like his, it should be interpreted to cover his circumstances, rather than denying him coverage. Under these circumstances, the Sixth Circuit therefore determined that the District Court was correct to reverse the insurance plan’s determination to deny coverage and instruct the plan to provide reimbursement to B.H.

Plaintiffs bringing claims against insurance companies frequently face resistance and specious arguments for denials of their insurance needs. Tennessee motorcycle accident attorney Eric Beasley understands how insurance companies work and will fight aggressively to ensure that your claims for reimbursement or coverage are fully met. For more information on seeking compensation for your medical damages, contact the Law Office of Eric Beasley today at 615-859-2223.

Related Blog Posts:

Tennessee Supreme Court Clarifies Reasonable Medical Expenses In Personal Injury Case, Tennessee Personal Injury Blog, November 21, 2017.

Tennessee Court Denies Prisoner’s Negligence Claim After Attack, Tennessee Personal Injury Blog, August 8, 2017

Tennessee Court Upholds Conclusion That Officer Was Not Responsible For Accident, Tennessee Personal Injury Blog, July 7, 2017.