John Guthrie v. Prudential Insurance Co of Ame

625 F. App'x 158
CourtCourt of Appeals for the Third Circuit
DecidedSeptember 2, 2015
Docket14-3282
StatusUnpublished
Cited by1 cases

This text of 625 F. App'x 158 (John Guthrie v. Prudential Insurance Co of Ame) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Guthrie v. Prudential Insurance Co of Ame, 625 F. App'x 158 (3d Cir. 2015).

Opinion

OPINION **

FUENTES, Circuit Judge.

John Guthrie challenges the District Court’s decision granting summary judgment on his denial of benefits claim brought under ERISA. 1 For the reasons set forth below, we affirm. 2

L

In. the early morning hours of August 6, 2010, Corey Guthrie died following a single-vehicle accident in the state of Virginia. *160 He was last seen alive leaving a restaurant and bar about a mile from the crash. Police were dispatched to the scene, at approximately 12:59 a.m. and reported that Corey Guthrie ran his motorcycle off the road toward an embankment. The road was dry, had no defects, and there was no adverse weather that night. Corey Guthrie was taken to the hospital and pronounced dead at 1:37 a.m. A toxicology report completed after the accident stated that his blood alcohol ' concentration (“BAC”) was .0.14% and his vitreous hum-our alcohol level was 0.13%. 3 The legal blood alcohol limit in Virginia is 0.08%. 4

At the time of the accident, Corey Guthrie was employed by CÁCI International, Inc. and received insurance coverage for “Accidental Death and Dismemberment,” an insurance policy issued by Prudential. The plan provided for • coverage in the event of accidental death, with a benefit amount of $270,000. As the sole beneficiary, John Guthrie (Corey Guthrie’s father) filed a claim under the policy after his son’s death. Prudential denied the claim due to an exclusion in the policy that was triggered if, at the time'of the accident, the operator of the vehicle was legally intoxicated. Based on reports.from the accident, Prudential concluded that Corey Guthrie was above the legal blood alcohol limit when he crashed, ,

John Guthrie (“Guthrie”) appealed the decision, asserting that Prudential could not determine his son’s blood alcohol level at the time of the accident. Because of this, Guthrie argúed, Prudential could'not meet its burden of proving that the policy exclusion applied. 'In response, Prudential contacted the Commonwealth of Virginia Department of Forensic Science that had collected Corey Guthrie’s blood .and vitreous humour samples. 5 Prudential was informed that in order to receive'the requested information, it would need to subpoena the Commonwealth -and pay a service fee .to speak with any of the department’s, employees. Additionally, Prudential contacted the Medical Examiner’s Office to request the .same information but received.no response.

As a result, Prudential referred the matter internally and requested that Albert A. Kowalski, M.D., review the case to determine whether he could discern Corey Guthrie’s blood alcohol content at the time of the accident. Dr.- Kowalski’s- analysis consisted of a “retrograde extrapolation” in which he declared the rate of elimination could be determined within a reasonable degree of medical certainty. He noted that the rate of absorption could not be determined because there were several unknown variables, which included the type of beverage Corey Guthrie had been consuming prior to the 'accident, quantity of beverage,- time of last drink, and quantity of food ingested. Dr. Kowalski estimated the blood alcohol level using the vitreous humour alcohol level’ of .13% from the toxicology report and determined the range to be .10%-.12%. He added that at this level, Corey Guthrie would have expe-riénced 'significant impairment of motor skills, judgment,' speech, balance, vision, *161 reaction time and hearing, and that, at this level, the risk of a single-vehicle fatal car crash increases to 48 times that of a driver who had not consumed alcohol. Dr. Kow-alski concluded that Corey Guthrie’s physical impairments led to “a direct causal connection between the insured’s level of intoxication and the motorcycle accident(of 08/06/10 and his death.” 6 After reviewing the information, Prudential denied Guthrie’s appeal.

The District Court determined that Prudential’s denial of the claim due to Corey Guthrie’s intoxication at the time of his death was supported by substantial evidence in the record. The District Court explained that Guthrie did not present any evidence suggesting that his son was not legally intoxicated at the time of the accident. In the absence of such evidence, the District Court held Prudential reasonably relied on Dr. Kowalski’s analysis in assessing the claim for accidental death benefits and that the decision was neither arbitrary nor capricious. The District Court granted Prudential’s motion for' summary judgment and denied Guthrie’s motion. This appeal followed.

n.

When reviewing a grant- of summary judgment, we apply the same standard as the District Court. Moreover, our review of an appeal from entry of summary judgment is plenary. 7 We may affirm the District Court’s decision if “the moving party is entitled to judgment as a matter of law, with the facts, reviewed in the light most favorable to the non-moving party.” 8 “We review a decision denying benefits under an arbitrary and capricious standard of review where, as here, the administrator has discretionary authority to determine eligibility for benefits”, and, we will affirm an administrator’s decision unless “it is without reason, unsupported by substantial evidence or erroneous as a matter of law.” 9 The.scope of this review is deferential to the benefits provider, and “the court is not free to substitute its own judgment .for that of the defendants in determining eligibility for plan benefits.” 10

On appeal, Guthrie asserts two .arguments: (1) that the District Court erred by failing to give weight to his structural conflict-of-interest argument due to Prudential’s role as both claim payer and claim evaluator; and (2) that the District Court erred by failing to assess Prudential’s burden of proof in light of flawed science and questionable evidence. We address each claim in turn.

A.

Guthrie argues that the District Court failed to adequately consider Prudential’s role as both claim payer and claim evaluator. We disagree. In Metropolitan Life Insurance Co. v. Glenn, the Supreme Court acknowledged that this type of dual role “creates a conflict of interest” and that conflict should be considered “as a factor in determining whether the plan administrator has abused its discretion in denying benefits.” 11 Here, *162 the District Court examined the inherent conflict of interest as a factor. In doing so, it, however, recognized that “not every conflict of this sort will be significant” and found “no evidence in the record to accord this factor special emphasis.” 12

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Bluebook (online)
625 F. App'x 158, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-guthrie-v-prudential-insurance-co-of-ame-ca3-2015.