The appellant insurer appealed a declaration requiring payment of life insurance proceeds to the respondent, who was the named beneficiary under a policy maintained pursuant to a separation agreement.
The insured died accidentally from cocaine intoxication after ingesting narcotics, and the insurer argued both an implied contractual exclusion for criminal acts and a public policy bar against recovery flowing from criminal conduct.
The Court of Appeal held the policy was unambiguous, the insured did not intend to cause his own death, and the respondent claimed as an ordinary beneficiary rather than through the insured's estate.
Applying prior authority on the crime-profit rule, the court held that public policy did not bar recovery by an innocent beneficiary and dismissed the appeal.
