Appeals court rejects accidental death claim under ERISA-governed plan
The issue was determining how exactly a doctor who vanished while mountain climbing died.
A federal appeals court case could affect what happens when people insured by group accidental death and dismemberment policies die but cannot be found.
A three-judge panel at the 11th U.S. Circuit Court of Appeals ruled last week that the sons of Dr. Alexander Goldfarb-Rumyantzev, a 57-year-old nephrologist who died in January 2021 while climbing the Broad Peak mountain in Pakistan, cannot collect $500,000 in accidental death and dismemberment policy benefits from the insurer, Reliance Standard Life.
Reliance Standard conceded in a motion asking a district court judge in Florida for summary judgment that Goldfarb-Rumyantzev has died. The insurer also conceded that the cause of the death was not suicide. But the insurer said the insured’s sons, Levi and Benjamin Goldfarb, have no evidence that the cause of death was accidental.
The district court judge granted summary judgment in favor of the Goldfarbs. Reliance Standard filed an appeal.
Chief Judge William Pryor wrote in an opinion for the three-judge panel that Reliance Standard was administering the plan under federal Employee Retirement Income Security Act rules. ERISA requires the federal courts to defer to ERISA plan administrators’ decisions when the decisions are not arbitrary and capricious.
Reliance Standard had a reasonable basis for denying the AD&D claim, Pryor writes in the opinion.
“Because this is a conclusion of law, Reliance Standard is entitled to summary judgment on the Goldfarbs’ claim,” Pryor says.
Goldfarb-Rumyantzev worked at Beth Israel Deaconess in Boston and taught at Harvard. He obtained the AD&D coverage through another employer, a pharmaceutical research company, according to a copy of the policy filed with the district court.
The policy contained no exclusion for mountain climbing.
Related: 10 states with the most preventable injury-related deaths
Goldfarb-Rumyantzev disappeared while climbing. Rescuers in a helicopter saw what appeared to be a lifeless body. His climbing partner said the body was Goldfarb-Rumyantzev’s body. Follow-up missions on the ground later found a boot but not the man’s body.
Levi and Benjamin Goldfarb have argued that courts have ruled in favor of the policy beneficiaries in comparable AD&D cases.
Reliance Standard could not be reached for comment.
Lawrence Metsch, the attorney for the Goldfarbs, said he is disappointed by the ruling and planning to ask for a rehearing.