On an appeal in a life insurance coverage dispute, the court considered whether a policy covering death by “accidental means” was narrower than coverage for “accidental death”.
The court held the phrases have essentially the same meaning and both turn on whether death was unexpected, with the central inquiry being whether the insured expected to die.
Where the insured’s actual expectation is unclear, the court may consider whether a reasonable person in the insured’s position would have expected death.
Applying that approach, the court found the overdose resulted from a miscalculation rather than an expected death, and upheld coverage under the accidental death benefit provision.
