Tran v. Minnesota Life Ins. Co.

Dist. Ct. erred in entering judgment in favor of plaintiff-wife of insured in ERISA action alleging that defendant-insurance company had wrongfully failed to pay accidental death and dismemberment benefits, where insured had died while performing autoerotic asphyxiation, which is sexual practice by which insured purposefully restricted blood flow to his brain to induce feeling of euphoria. While Dist. Ct. found that insured’s death qualified as accidental death that did not result from intentionally self-inflicted injury, Ct. of Appeals found autoerotic asphyxiation qualified as intentional self-inflicted injury that precluded coverage under relevant accidental death and dismemberment policy riders. (Dissent filed.)