Case Summary

The insured, a physician with a history of opiate addiction, died from an intravenous injection of Demerol. His life insurance policy provided coverage for death effected through 'accidental means'. The insurer denied the claim, arguing the self-injection was a deliberate act. The Supreme Court of Canada held that 'accidental means' does not refer to a narrower subclass of 'accidental deaths'. Both phrases connote a death that was unexpected. The Court found that the insured did not expect to die but made a miscalculation regarding the dosage. The appeal was dismissed, and the beneficiary was entitled to the accidental death benefit.