Opinion
GEORGE, J.
In this case we must determine whether a life insurance policy covering loss of life occurring as the direct result of bodily injury inflicted solely by “external, violent and accidental means” provides coverage when the insured’s voluntary ingestion of cocaine resulted in a lethal overdose. Plaintiffs, beneficiaries of the insured, contend that the drug overdose was accidental and therefore that the policy provides coverage. Because the insured’s voluntary ingestion of an illegal and dangerous substance caused his death, defendant insurer contends death did not result from bodily injury inflicted solely by “accidental means,” within the terms of the insurance policy.
We conclude, first, that the distinction in policy language between “accidental means” and “accidental results,” recognized in our prior decisions, should be preserved, and second, that the voluntary ingestion of a known hazardous and illegal substance does not provide a basis for coverage within the terms of an insurance policy affording coverage for death by “accidental [130]*130means.” Accordingly, we reverse the judgment of the Court of Appeal affirming the trial court’s entry of summary judgment in favor of plaintiffs, and direct the Court of Appeal to remand this action to the trial court.
I
On April 14, 1975, defendant Federal Kemper Life Assurance Company issued a life insurance policy to the employer of Michael P. Weil, the deceased, naming Weil as the insured. The policy provided insurance on Weil’s life, affording a benefit of $100,000. The policy included an “Additional Accidental Death Benefit” supplementary rider, affording an additional benefit of $100,000 in the event the insured’s death occurred solely by accidental means and no other terms in the “rider” excluded coverage based upon the circumstances of the death.1 Plaintiffs Lola and Michelle Weil (Michael Weil’s mother and sister, respectively) are the beneficiaries named in the policy.
The supplementary rider to the policy provides in pertinent part as follows: “Benefits—The Company agrees, subject to the provisions of this Policy, to immediately pay to the Beneficiary or Beneficiaries, in addition to the other benefits provided by this Policy, the amount of additional accidental death benefit specified in the Policy Specifications, if due proof is furnished to the Company at its Home Office that the Insured, while this Policy is in full force and effect, has suffered the loss of life as the direct result of bodily injury, independent of all other causes, effected solely through external, violent and accidental means, as evidenced by a visible contusion or wound on the exterior of the body (except in the case of drowning or internal injuries revealed by an autopsy), and that the date of death occurred within ninety days after such injury.” (Italics added.) In another section, the rider also provides in relevant part: “Risks Not Assumed—The Company shall not be liable for any payment hereunder if the Insured’s death: ... [1] B. Results directly or indirectly from any of the following causes: [1] . . . [1] (2) suicide, sane or insane, or any attempt thereat; H] . . . H] (4) committing an assault or felony; ffl . . . or [f] (6) disease or bodily or mental infirmity or medical or surgical treatment therefor . . . ,”2
Michael Weil died on August 17, 1985, in a hotel room in San Francisco. The cause of death was described on the death certificate as acute cocaine [131]*131poisoning. Defendant paid the $100,000 basic benefit provided in the policy to plaintiffs as beneficiaries, but denied plaintiffs’ claim for the additional $100,000 benefit, described in the accidental death supplementary rider, on the grounds that Mr. Weil’s death did not occur solely by accidental means within the meaning of the policy, and fell within the policy exclusion for a death resulting directly or indirectly from the commission of a felony.
On March 31, 1987, plaintiffs brought an action against defendant, seeking declaratory relief as well as damages for breach of contract, breach of the implied covenant of good faith and fair dealing, and violation of Insurance Code section 790.03, subdivision (h).
On June 30, 1989, plaintiffs moved for summary judgment or summary adjudication of issues. In contending that Mr. Weil’s death constituted death by accidental means as a matter of law, plaintiffs advanced alternative factual positions. They asserted that, even if the cause of death had been acute cocaine poisoning from voluntary ingestion of cocaine, as indicated by the statements in the death certificate and other reports produced by defendant, Mr. Weil’s death occurred by accidental means within the meaning of the policy, because he did not intend to injure himself or cause his own death. Alternatively, they asserted, a probability existed that “unforeseen acts” intervened to cause Mr. Weil’s death, in view of the following circumstances: (1) near the time of his death, Mr. Weil had been prescribed and may have been taking the drug Darvocet (to ameliorate pain caused by gum disease), (2) after death his body was identified by an individual (whom the police subsequently were unable to locate) who was unknown to Mr. Weil’s family and coworkers, and (3) Mr. Weil’s condominium (located in Santa Clara) had been burglarized during the weekend of his death. Plaintiffs also contended that Mr. Weil’s death was caused not by possession of cocaine, a felony (Health & Saf. Code, §§ 11054, subd. (f)(1), 11350), but by ingestion or use of cocaine, a misdemeanor (Health & Saf. Code, § 11055, subd. (b)(4)).
Defendant filed an opposition and, upon obtaining leave of the court, filed its own motion for summary judgment or summary adjudication of issues, on the theories that, as a matter of law, Mr. Weil’s death did not result from “accidental means,” and, furthermore, that his death resulted directly or indirectly from the commission of a felony. In support of its motions, defendant presented evidence that on the afternoon of Mr. Weil’s death, a female prostitute summoned to his hotel room observed that he appeared to be under the influence of drugs, inquired whether that was the case, but [132]*132received his assurance that he “would be all right.” Approximately one hour later, she observed him ingest cocaine from a dish in the bathroom of the hotel room. He then suffered shortness of breath and collapsed, and subsequent attempts by paramedics to revive him proved to be unsuccessful. The medical examination performed on his body revealed no evidence of trauma. Chemical analyses disclosed the presence of cocaine in his system, but no Darvocet. A sample apparently taken from the dish recovered from the hotel bathroom tested positive for cocaine.
The motions were heard and taken under submission on August 25, 1989. In a minute order entered September 19, 1989, the superior court summarily adjudicated that the subject life insurance policy had been issued to the decedent, that its supplementary rider provided an additional benefit of $100,000, and that plaintiffs were entitled to that additional benefit. The court determined as a matter of law that Mr. Weil’s death, from an unintentional overdose of cocaine, resulted from “accidental means” within the meaning of the policy. The court also determined that Mr. Weil’s death did not result directly or indirectly from the commission of a felony, possession of cocaine, but rather from misdemeanor use of cocaine. Nonetheless, the court denied plaintiffs’ motion for summary judgment on the ground that triable issues of fact remained as to whether defendant, in denying the supplemental accidental death benefit, breached the implied covenant of good faith and fair dealing. The court also denied defendant’s motion for summary judgment.
Thereafter, plaintiffs dismissed with prejudice their causes of action for breach of the implied covenant of good faith and fair dealing and for violation of Insurance Code section 790.03, subdivision (h). On February 6, 1991, the parties filed a stipulation with the court, requesting that it enter judgment on the remaining cause of action for breach of the insurance agreement and on the request for declaratory relief. That stipulation includes the statement: “All motions were heard on August 25, 1989. At the hearing, all parties stipulated that the motions presented pure questions of law and that the facts were undisputed.” The court on February 6, 1991, entered judgment in favor of plaintiffs, declaring their entitlement to the $100,000 additional death benefit under the supplementary rider, and further declaring that no exclusion applied, because Mr. Weil’s death did not result directly or indirectly from the commission of a felony.
Defendant appealed, contending that the superior court erred in its interpretation of the coverage clause of the supplementary rider, because the death of an insured caused by his or her voluntary ingestion of an illegal and dangerous substance, such as cocaine, is not the result of an injury occurring [133]*133solely by “accidental means” within the meaning of such an insurance policy. Defendant also urged that plaintiffs had not established that acts other than Mr. Weil’s voluntary ingestion of cocaine had intervened to cause his death, and additionally contended that the exclusion for commission of a felony applied. In a divided decision that produced three separate opinions, the Court of Appeal affirmed the judgment, and we subsequently granted defendant’s petition for review.
II
Before this court, defendant renews its argument that the superior court erred in determining that the death of an insured, caused by his ingestion of an illegal and dangerous substance, may be considered the result of means within the meaning of the policy, simply because the insured did not intend to kill himself. Defendant relies upon a series of decisions by this court and the Courts of Appeal, applying similar policy language, that have distinguished policies affording coverage for death resulting from bodily injury effected through “accidental means” from policies providing coverage for “accidental death.” In particular, defendant relies upon Hargreaves v. Metropolitan Life Ins. Co. (1980) 104 Cal.App.3d 701 [163 Cal.Rptr. 857], in which the Court of Appeal concluded that an experienced heroin user, who injected heroin immediately prior to his death, did not die by “accidental means” as defined in the policy insuring his life. (Id. at p. 708.)3
Plaintiffs have two responses. First, they contend that (assuming Mr. Weil died solely as the result of his voluntary ingestion of cocaine) the distinction between the coverage afforded by “accidental means” policies and death” policies should be abolished. Plaintiffs point out that the between the two types of policies has been the subject of long-standing criticism. They urge that retention of the distinction is inconsistent with the general principle of California insurance law providing that insurance generally are to be interpreted in accordance with the reasonable expectations of the ordinary insured&emdash;who reasonably would anticipate that both types of policies would provide coverage when death is caused by an “accident.” Second, even if the court retains the distinction between means” and “accidental death” policies, plaintiffs contend that a number of cases have interpreted “accidental means” policies to afford coverage when some unexpected event occurs that joins with the insured’s [134]*134conduct to cause death, and (again assuming death from voluntary consumption) they contend that an unintended drug overdose constitutes such an unexpected event.4
Accordingly, in determining whether summary judgment in favor of plaintiffs should be upheld, we shall consider (1) whether the distinction between “accidental means” and “accidental death” policies should be retained, and (2) whether the policy properly should be interpreted to provide coverage for an unintentional death resulting from the voluntary ingestion of an illegal and dangerous substance.
Ill
California long has recognized the limiting effect of language in insurance policies providing coverage in the event death occurs by “accidental means.”5 For example, in Rock v. Travelers’ Insurance Co. (1916) 172 Cal. 462, 463 [156 P. 1029], the policy afforded coverage if the death of the insured was the result of “ ‘bodily injury effected directly and independently of all other causes, through external, violent, and accidental means.’ ” The insured collapsed and died after carrying, with another man, a funeral casket down a flight of stairs. In articulating the difference between insuring against accidental death and insuring against death by accidental means, this court stated: “The policy, it will be observed, does not insure against accidental death or injuries, but against injuries effected by accidental means. A differentiation is made, therefore, between the result to the insured and the means which is the operative cause in producing this result. It is not [135]*135enough that death or injury should be unexpected or unforeseen, but there must be some element of unexpectedness in the preceding act or occurrence which leads to the injury or death. ... ‘A person may do certain acts, the result of which acts may produce unforeseen consequences and may produce what is commonly called accidental death, but the means are exactly what the man intended to use, and did use, and was prepared to use. The means were not accidental, but the result might be accidental.’ ” (Id. at p. 465, italics added; see also Zuckerman v. Underwriters at Lloyd’s (1954) 42 Cal.2d 460, 476 [267 P.2d 777] [noting that, in a proper case, the distinction should be made between “accidental means” and “accidental death”].)
In determining whether the means of death or injury may be said to be accidental when, immediately preceding death, the insured was engaged in a voluntary act, some of our prior decisions have focused upon the presence or absence of a slip, mishap, or mischance—that is, something accidental that happens during the voluntary act, or another accidental event that intervenes to cause death. If such a mishap occurs, then the death may be said to transpire through accidental means. (E.g., Rock v. Travelers’ Insurance Co., supra, 172 Cal. 462, 464-468 [means were not accidental where no mishap occurred while the insured carried the casket downstairs, causing his collapse and death]; Ogilvie v. Aetna Life Insurance Co. (1922) 189 Cal. 406, 409-412 [209 P. 26, 26 A.L.R. 116] [no accidental means where a plow operated by the insured made no unusual lurch, sway, or swing, and the insured’s fatal heart rupture was caused by strain naturally incident to plowing]; Olinsky v. Railway Mail Assn. (1920) 182 Cal. 669, 670-673 [189 P. 835, 14 A.L.R. 784] [means were not accidental where the insured voluntarily swam upstream, overexerting himself against a strong current, and there was no evidence of a slip].)
In making the foregoing determination, a number of California decisions have focused particularly upon whether the insured’s voluntary act itself is such that its common, natural, or probable consequence would be to visit injury or death upon the insured. If not, then the death may be considered to have occurred through accidental means. (E.g., Harloe v. California State Life Ins. Co. (1928) 206 Cal. 141, 142 [273 P. 560] [no accidental means, because the effect, a fatal sunstroke, was a “natural and probable consequence” of the insured’s act of repairing a waterline in 110-degree heat]; Postler v. Travelers Ins. Co. (1916) 173 Cal. 1, 3-6 [158 P. 1022] [no accidental means where the insured’s death in gun duel was a natural and probable consequence of drawing a firearm and chasing an armed man while attempting to recover money lost in gambling], overruled on another ground in Zuckerman v. Underwriters at Lloyd’s, supra, 42 Cal.2d 460, 474; Cox v. Prudential Ins. Co. (1959) 172 Cal.App.2d 629, 635-636 [343 P.2d 99] [136]*136[accidental means were present in death of the insured arrestee who escaped from moving police vehicle, landing between front and rear wheels of a truck travelling in the opposite direction, because the insured did not know, and could not reasonably have anticipated, that he would be struck by the wheels]; Rooney v. Mutual Benefit H. & A. Assn. (1946) 74 Cal.App.2d 885, 889-890 [170 P.2d 72] [recovery permitted where the means employed by the insured (attempting to strike another with his fist) produced effects (the insured’s death by hitting his head on the ground after his opponent retaliated by striking him and knocking him down) “ ‘which are not their usual and probable consequences’ ”]; Losleben v. California State L. Ins. Co. (1933) 133 Cal.App. 550, 554-557 [24 P.2d 825] [means were accidental where the insured jumped from three-foot-high bench, twisted small intestine, developed peritonitis, and died, because the effect upon the insured, which was not such as ordinarily would follow or be expected from an act of this nature, established that the means producing the injury contained something of an unexpected character]; Davilla v. Liberty Life Ins. Co. (1931) 114 Cal.App. 308, 313-316 [299 P. 831] [means were accidental where the insured motorcycle policeman swerved to avoid, but hit his head on, a stalled vehicle, because the insured “ ‘could not reasonably have anticipated, and did not intend to produce,’ ” an act causing his own death]; Horton v. Travelers Ins. Co. (1920) 45 Cal.App. 462, 466-469 [187 P. 1070] [means were accidental where the insured’s death was caused by a dentist’s use of contaminated dental instruments; danger was unknown, and the introduction of germs causing blood poisoning is not a natural and probable consequence of the use of dental instruments by a dentist].)
Whether a court’s decision has focused solely upon the absence of a slip, mishap, or mischance in the performance of, or in intervention of, the insured’s voluntary act, or also upon whether the voluntary act is such that its common, natural, or probable consequence is fatality or serious injury, it is clear that California cases in a variety of factual settings have interpreted policies affording coverage for death effected through accidental means to preclude coverage for voluntary and intentional conduct that results in unintended death.
In several diversity jurisdiction cases, the United States Supreme Court also expressly has recognized the distinction between policies affording coverage for accidental death and coverage arising only where death is caused by accidental means. (Landress v. Phoenix Ins. Co. (1934) 291 U.S. 491, 495-498 [78 L.Ed. 934, 936-938, 54 S.Ct. 461, 90 A.L.R. 1382]; Mutual Accident Association v. Barry (1889) 131 U.S. 100, 121-122 [33 L.Ed. 60, 66-67, 9 S.Ct. 755].) In Landress v. Phoenix Ins. Co., supra, 291 U.S. 491, 495 [78 L.Ed. 934, 936], the beneficiary, whose insured had died of sunstroke suffered while playing golf, sought recovery under two such policies, [137]*137one of which, in language nearly identical to that set forth in the subject policy, provided indemnity in the event death should result “directly and independently of all other causes from bodily injuries effected through external, violent and accidental means . . .
In response to the beneficiary’s argument that death resulting from voluntary exposure to the sun’s rays was accidental in the common or popular sense of the term, the majority observed: “[I]t is not enough, to establish liability under these clauses, that the death or injury was accidental in the understanding of the average man—that the result of the exposure ‘was something unforeseen, unsuspected, extraordinary, an unlocked for mishap, and so an accident,’ [citations]—for here the carefully chosen words defining liability distinguish between the result and the external means which produces it. The insurance is not against an accidental result. . . . The external means is stated to be the rays of the sun, to which the insured voluntarily exposed himself.” (291 U.S. 491, 495-496 [78 L.Ed. 934, 936].) The majority thus affirmed the decision of the lower court that the beneficiary was not entitled to recover on the policy. (Id. at p. 498 [78 L.Ed.2d at pp. 937-938].)
Cautioning in his dissent that “[t]he attempted distinction between accidental results and accidental means will plunge this branch of the law into a Serbonian Bog” (291 U.S. 491, 499 [78 L.Ed. 934, 938] (dis. opn. of Cardozo, J.)),6 Justice Cardozo took the position that the insured’s demise from sunstroke—the unusual effect of a known cause—was a death by accidental means. “When a man has died in such a way that his death is spoken of as an accident, he has died because of an accident, and hence by accidental means. ... So the holder of this policy might reasonably assume.” (291 U.S. at pp. 499-500 [78 L.Ed. at p. 938], fn. omitted.)
Nonetheless, as described above, California decisions have adhered to the distinction recognized by the majority in Landress v. Phoenix Ins. Co., supra, as have the courts in numerous other jurisdictions. (3 Harnett & Lesnick, supra, § 7.03[1], pp. 7-24 to 7-29; id., (1992 supp.) p. 5.) Although, as we have noted, these cases have employed several analytical approaches in determining whether death has resulted from injury caused by accidental means, such decisions have continued to recognize and apply the distinction between death by accidental means and accidental death.
[138]*138Plaintiffs have urged that we take this opportunity to join “an increasing number” of jurisdictions in rejecting the distinction between “accidental death” and “accidental means.” As noted in one treatise, “Many jurisdictions followed the distinction between accidental result and accidental means set forth in Barry and in the Landress majority opinion, and for some time, the rule of distinction remained a clear-cut majority view. But the courts continued to have problems with the distinction, both in applying it and in the outcomes that were reached when it was applied. As neither Barry nor Landress involved a federal question, but were diversity cases with their reference to state law, the courts were not required to follow either case, and they began to question the advisability both of following those decisions and grappling with the distinction. Many jurisdictions found the distinction unworkable and unrealistic, and a trend began away from the distinction and toward Justice Cardozo’s dissent.” (3 Harnett & Lesnick, supra, § 7.02[4], pp. 7-20 to 7-21, fns. omitted; see Annot., Death or Injury From Taking Illegal Drugs or Narcotics as Accidental or Result of Accidental Means Within Insurance Coverage (1972) 41 A.L.R.3d 654, 657; Annot., Death or Injury Resulting From Insured’s Voluntary Act in Taking Overdose of Medicine, Drugs, or the Like, as Caused by Accident or Accidental Means (1957) 52 A.L.R.2d 1083, 1086-1087; Annot., Insurance: “Accidental Means” as Distinguishable From “Accident,” “Accidental Result,” “Accidental Death,” “Accidental Injury,” etc. (1947) 166 A.L.R. 469, 471, fn. 7, 473, fn. 20.)
It appears that, as of 1992,22 jurisdictions, including California, expressly recognized the distinction between “accidental means” and “accidental death” (3 Harnett & Lesnick, supra, § 7.03[1], pp. 7-24 to 7-29; id., (1992 supp.) p. 5), whereas 25 jurisdictions expressly have rejected or repudiated this distinction. (3 Harnett & Lesnick, supra, § 7.06[1], pp. 7-112 to 7-116.) In addition, the United States Court of Appeals, First Circuit, in developing federal common law (for application to Employee Retirement Income Security Act (ERISA) governed insurance policies), recently indicated it will follow the line of cases that decline to draw the foregoing distinction. (Wickman v. Northwestern Nat. Ins. Co. (1st Cir. 1990) 908 F.2d 1077, 1086.) Thus, California now appears to be in a slight minority in recognizing a distinction between the coverage provided by “accidental means" and “accidental death” policies.
Plaintiffs emphasize the courts’ obligation to interpret and apply “accidental means” coverage in a manner consistent with the reasonable expectations of insureds, urging that if this court were to repudiate the distinction between coverage for “accidental means” and “accidental death,” the result would reflect more clearly the ordinary person’s understanding of such policy language, as suggested by Justice Cardozo. (AIU Ins. Co. v. Superior Court [139]*139(1990) 51 Cal.3d 807, 822 [274 Cal.Rptr. 820, 799 P.2d 1253] [coverage clauses interpreted broadly to protect objectively reasonable expectations of the insured]; see also Bank of the West v. Superior Court (1992) 2 Cal.4th 1254, 1264-1265 [10 Cal.Rptr.2d 538, 833 P.2d 545] [uncertainties interpreted to protect objectively reasonable expectations of the insured]; Southwestern Funding Corp. v. Motors Ins. Corp. (1963) 59 Cal.2d 91, 94 [28 Cal.Rptr. 161, 378 P.2d 361] [any uncertainties resolved against the insurer and in favor of imposing liability].)
Nonetheless, we must bear in mind that normally the content of an insurance policy is within the control of the parties. Unless the limitation of coverage of “accidental means” policies to a narrower class of cases than is covered by “accidental death” insurance would violate a particular statute or other express public policy, it is not our proper role to mandate that the two types of policies be interpreted as coextensive. By repudiating the the court in effect would be ignoring the fact that the policy does employ the word “means.” (3 Harnett & Lesnick, supra, § 7.03[2], pp. 7-30 to 7-31.)
Several cases from other jurisdictions have admonished that disregarding the “means” language by equating it with accidental results does not take account of the contract language (Linden Motor Freight Co., Inc. v. Traveler’s Ins. Co. (1963) 40 N.J. 511 [193 A.2d 217, 224] [also observing that the average policyholder would appreciate that an “accidental means” policy refers to accidental cause and not to every unforeseen, unexpected, unusual loss, especially since the premium charged is small (id., 193 A.2d at pp. 224-225)]; McGinley v. John Hancock Mut. Life Ins. Co. (1936) 88 N.H. 108 [184 A. 593, 595])&emdash;or requires a forced or strained construction of contract language (John Hancock Mut. Life Ins. Co. of Boston v. Plummer (1942) 181 Md. 140 [28 A.2d 856, 857]; Gidlund v. Benefit Ass’n. of Ry. Employees (1941) 210 Minn. 176 [297 N.W. 710, 712]; see 3 Harnett & Lesnick, supra, § 7.03[2], pp. 7-31 to 7-33).
Moreover, although plaintiffs contend that the phrase "accidental means" is "inherently ambiguous and creates a reasonable doubt as to the peril insured against," with regard to the use of this specific phrase in a number of insurance policies this court "has consistently, uniformly and repeatedly interpreted insurance policies providing benefits for death or injury effected through "accidental means" without once having suggested that the insuring words were ambiguous. The Courts of Appeal similarly have failed to find any ambiguity or uncertainty in the coverage provided by such policies. . . .` [Citation.]" (Hargreaves v. Metropolitan Life Ins. Co., supra, 104 Cal.App.3d 701, 705.) In Rock v. Travelers' Insurance Co., supra, [140]*140172 Cal. 462, we termed the language of such policies “plain.” (Id. at p. 467.)
It also is the case that in jurisdictions (such as California) that have developed the distinction between “accidental means” and “accidental results,” policies requiring only that there be proof of accidental death have been construed broadly, “such that the injury or death is likely to be covered unless the insured virtually intended his injury or death,” perhaps because the insurer could have limited its liability by employing the “accidental means” language. (3 Harnett & Lesnick, supra, § 7.05[3], p. 7-96; e.g., Collins v. Nationwide Life Ins. Co. (1980) 409 Mich. 271 [294 N.W.2d 194, 196-197].) In view of these considerations, we do not consider it appropriate at this late date to reinterpret such policy language in order to eradicate this distinction.
The argument also has been made that we should abolish the distinction in order to resolve the apparent dichotomy that has developed in California cases in viewing the test of “accidental means” as involving either (1) a scrutiny of the circumstances surrounding the insured’s voluntary act for . evidence of an accidental element or an intervening accident, or (2) a scrutiny of the insured’s voluntary act in terms of its consequences, in deciding the accidental nature of the act based upon the probability of those consequences.
As described above, certain of this court’s early decisions adopted and employed the concept that the means are not accidental when the insured performs a voluntary act, unless something accidental (slip, mishap, or mischance) happens during the act, or another accidental event intervenes, causing death. (E.g., Ogilvie v. Aetna Life Insurance Co., supra, 189 Cal. 406, 409-412; Olinsky v. Railway Mail Assn., supra, 182 Cal. 669, 670-673; Rock v. Travelers’ Insurance Co., supra, 172 Cal. 462, 465.) A number of other decisions by this court and the Courts of Appeal focus or base their holdings upon a standard indicating that the means are not accidental when the natural, probable, or to-be-expected result of the voluntary behavior is to bring death or injury upon the insured. (E.g., Harloe v. California State Life Ins. Co., supra, 206 Cal. 141, 142; Cox v. Prudential Ins. Co., supra, 172 Cal.App.2d 629, 635-636; Rooney v. Mutual Benefit H. & A. Assn., supra, 74 Cal.App.2d 885, 889-890; Losleben v. California State L. Ins. Co., supra, 133 Cal.App. 550, 554-557; Davilla v. Liberty Life Ins. Co., supra, 114 Cal.App. 308, 313-316.)
Essentially, the approach embodied in the latter line of cases is to consider the probability of the result in deciding whether the voluntary action of the [141]*141insured preceding the injury can constitute “accidental means.” This consideration has been criticized, because it appears inconsistent with the cases determining that “accidental means” are present only where there occurs some slip, mishap, or mischance in the performance (or intervention) of a voluntary act (see Comment, The Judicial Approach to “Accidental Means” Policies in California, supra, 13 Hastings L.J. 255, 260-272), and because such a consideration appears effectively to merge with the “accidental result” test employed in cases reviewing coverage under accidental death policies. (Ibid.; 3 Harnett & Lesnick, supra, § 7.04[3], pp. 7-45 to 7-49.)
Nonetheless, we believe that in determining whether the means properly may be described as accidental, both considerations validly may be invoked in particular cases. In Landress v. Phoenix Ins. Co., supra, 291 U.S. 491, 496-497 [78 L.Ed. 934, 936-937, 54 S.Ct. 461], the majority, although relying upon the absence of any slip, mishap, or mischance in concluding the insured’s death by sunstroke did not constitute death by accidental means, expressly did not foreclose the possibility that in other circumstances an unforeseen, and hence accidental, result might give rise to the inference that the external means also were accidental. (Id. at pp. 496-497 [78 L.Ed. at pp. 936-937].) Moreover, although it has been suggested that the standard propounded in Justice Cardozo’s dissent would find an effect to be accidental as a matter of law if it is not the natural or probable consequence of the means that produced it (Id., at pp. 500-501, fn. 2 [78 L.Ed. at p. 939] (dis. opn. of Cardozo, J.); see Linden Motor Freight Co., Inc. v. Traveler’s Ins. Co., supra, 40 N.J. 511 [193 A.2d 217, 222]), under our prior decisions the improbability of the outcome or effect is simply one consideration that must be taken into account in determining whether a death or injury resulted from “accidental means.” In our jurisdiction, as described more folly below, the court in Hargreaves v. Metropolitan Life Ins. Co., supra, 104 Cal.App.3d 701, without apparent inconsistency, incorporated both approaches, basing its decision that a death by heroin overdose was not covered under an “accidental means” policy upon the voluntariness of the act of injecting the heroin, the absence of any slip, mishap, or mischance, and the circumstance that the deceased knew or should have known that death was a “probable,” “not unexpected” consequence of his voluntary act. (Id. at p. 708.) Thus, even when the evidence does not disclose an intervening accident or an accidental element, it is appropriate, in determining whether death occurred by accidental means, to consider whether an effect is not the natural, probable, or expected consequence of the means that produced it. (See Losleben v. California State L. Ins. Co., supra, 133 Cal.App. 550, 554-557; Davilla v. Liberty Life Ins. Co., supra, 114 Cal.App. 308, 313-316.)
IV
We now turn to the question whether a death arising from a voluntary, self-inflicted, but unintentional overdose of an illegal substance [142]*142may be considered “the direct result of bodily injury, independent of all other causes, effected solely through external, violent and accidental means,” as described in the supplementary rider involved in the present proceedings.
In conformity with prior California decisions, the court in Hargreaves v. Metropolitan Life Ins. Co., supra, 104 Cal.App.3d 701, applied the distinction between “accidental means” and “accidental death,” synthesizing the two approaches that had been developed in those cases for the purpose of ascertaining whether the means by which death had occurred were accidental. In concluding that the death of an experienced heroin user by overdose did not occur by “accidental means” within the meaning of a life insurance policy, the court based its decision upon (1) the voluntariness of the act (the heroin user “obviously intentionally injected himself with heroin, a death dealing substance”), (2) the absence of any slip, mishap, or mischance (‘there is absolutely no evidence justifying an inference that in utilizing the means (hypodermic needle) there were other acts (or act) containing unforeseen or unexpected character unintentionally done by him”), and (3) the circumstance that death reasonably could be anticipated (“he knew or should have known that illicit use of heroin is injurious to the body and as a practical matter when illicitly used in whatever amount a probable result not unexpected is death”). (Id. at p. 708.)
Assuming, for the moment, that we accept the formulation of the court in Hargreaves that the means may not be considered accidental if the insured knew or should have known that death or injury therefrom was probable and not unexpected, it is apparent under the present line of California decisions (including Hargreaves) that recognize the distinction between coverage for death by “accidental means” and coverage for “accidental death,” that the death of an insured caused by his or her voluntary consumption of an illegal and dangerous substance, without mishap, would not be considered the result solely of external, violent, and accidental means. Accordingly, defendant is correct in asserting that the superior court erred in determining that, simply because death itself was unintended, an unintentional overdose may comprise “accidental means” within the meaning of such a policy.
We are aware of the seemingly contrary decision in Pilcher v. New York Life Ins. Co. (1972) 25 Cal.App.3d 717 [102 Cal.Rptr. 82], relied upon by the superior court in the present case. Noting that, in those jurisdictions that have repudiated the distinction between “accidental means” and “accidental death,” the insurer frequently has been held liable for an unintentional drug overdose, the court in Pilcher held that death by a self-administered overdose of heroin constituted “accidental death,” and therefore held the insurer liable under the accidental death policy at issue in that case. (Id. at pp. [143]*143725-727.) The court went on to suggest that, whether a policy covers death by “accidental means” or, instead, “accidental death,” an unintentional death resulting from an overdose of drugs would be covered. The court also asserted that, even in jurisdictions still applying the means test, the decisions “have held consistently” that if the insured took (as one decision described it) a greater quantity of a substance “ ‘than intended or realized,’ ” then death is by “accidental means” and the insurer is liable. (Id. at p. 723.) The foregoing suggestions by the Court of Appeal in Pilcher with regard to the coverage of an “accidental means” policy are only dicta, however, because the court had before it a policy covering “accidental death.” In any event, as we shall explain, we disagree with those suggestions.
The decisions that have interpreted policies insuring against death caused by “accidental means," in the situation in which an insured voluntarily, knowingly, and intentionally self-administers a given drug (whether prescribed or illegal), resulting in an unintentional fatal overdose, generally have applied one or the other of two distinct analyses in determining whether “accidental means” are present. The court either has inquired whether the insured intended or expected to ingest the quantity of the substance actually taken, or has inquired whether the insured was ignorant of the lethal nature of the amount taken (even if the insured intended to consume the quantity actually taken).
Occasionally, a decision has discussed both of these considerations. For example, in Metropolitan Life Ins. Co. v. Main (5th Cir. 1967) 383 F.2d 952, the insured, accustomed to taking one Medomin (a prescribed barbiturate sleeping pill) each night, celebrated a promotion by having four drinks of whiskey, and, having become confused, took four to eight Medomin, with a lethal result. Applying Connecticut law, the court held that the insured’s death occurred by “accidental means,” because he did not intend to take that dosage of Medomin and did not intend to ingest an amount of both substances sufficient to create the synergistic effect that brought about his death. (Id. at p. 960.)
More typically, however, courts, in arriving at a determination whether the means were accidental, have based their decisions upon only one of the foregoing two considerations. (See Feldmann v. Connecticut Mut. Life Ins. Co. etc. (8th Cir. 1944) 142 F.2d 628, 633 [applying prior New York law, the court held that death occurred by accidental means where the insured, accustomed to taking one capsule, had taken fifteen capsules of Nembutal, allegedly by mistake]; compare with Hawkins v. New York Life Ins. Co. of New York, N.Y. (1954) 176 Kan. 24 [269 P.2d 389, 398] [the insured died by accidental means where she was unaware that the quantity of barbiturates [144]*144taken was a lethal dose]; Hodgson v. Preferred Acc. Ins. Co. (1917) 100 Misc. 155 [165 N.Y.S. 293, 297-298] [the insured was considered to have died by accidental means where he was unaware the amount of morphine taken would produce a harmful effect]; Dezell v. Fidelity & Casualty Co. (1903) 176 Mo. 253 [75 S.W. 1102, 1102-1104] [the insured was considered to have died by accidental means where he intentionally and knowingly took morphine but did not intend or expect that death would result].)7
Nonetheless, a number of decisions, although recognizing that the insurer would be liable if the insured by accident took a greater quantity of a particular drug than he or she intended, have absolved the insurer in the situation in which the insured knowingly and intentionally took a certain quantity but simply was ignorant of the circumstance that death probably would ensue from ingesting that amount. Thus, in Carnes v. Iowa Traveling Men’s Ass’n. (1898) 106 Iowa 281 [76 N.W. 683], the court observed that the insured’s death by morphine overdose could be accounted for in two ways: either he had taken more morphine than he intended, or he had intended to take the amount he did, but misjudged its effect. Because the plaintiff was unable to rule out the second possibility, she did not meet her burden of establishing coverage under the policy. (Id., 76 N.W. at pp. 684-685; see also Murphy v. Western & Southern Life Ins. Co. (Mo.App. 1953) 262 S.W.2d 340, 342-343 [where there was no evidence that the insured took an excessive amount of paraldehyde because his foot slipped or because he was drunk and believed the liquid was whiskey, his ignorance of the effect of taking an amount in excess of that prescribed did not supply the element of unexpectedness that would render accidental the means of death]; Aubuchon v. Metropolitan Life Ins. Co. (8th Cir. 1944) 142 F.2d 20, 26 [under Missouri law, if the insured intended to consume the number of Veronal (barbiturates) he ingested, death did not occur by accidental means, even though the insured did not anticipate death would result from taking that amount].)
In general, the more recent cases in those jurisdictions that continue to recognize the distinction between “accidental means” and “accidental results,” have adopted the view that, where it appears an insured has consumed [145]*145or administered the quantity of a particular drug that he or she intended to ingest, death may not be said to have occurred by “accidental means,” even if the insured was ignorant that that amount constituted a harmful overdose. This conclusion most commonly has been reached where possession of the substance in question is illegal.
In our own jurisdiction, the decision in Hargreaves v. Metropolitan Life Ins. Co., supra, 104 Cal.App.3d 701, essentially adopts this approach. The conclusion of the appellate court that the death of an experienced heroin user by heroin injection did not constitute death by “accidental means” rested in part upon the determination that the drug apparently could not have been mistaken for a harmless substance, and upon the plaintiffs not having contested the trial court’s finding that the heroin injection was “ ‘done in the usual manner without any mishap.’ ” (Id. at p. 708.)
The court in Hargreaves additionally concluded, because of the high probability that serious consequences would arise from the conduct of the insured, that the means of death were not accidental. The court stated that the heroin user “knew or should have known that illicit use of heroin is injurious to the body and as a practical matter when illicitly used in whatever amount a probable result not unexpected is death . . . .” (Hargreaves v. Metropolitan Life Ins. Co., supra, 104 Cal.App.3d 701, 708.) We do not agree with, or adhere to, the pronouncement of the court in Hargreaves that death or serious injury is a probable result of ingestion of controlled substances, and believe it more accurate (taking into account the language employed in earlier California decisions) to describe such a result as common, natural, or substantially likely. The standard invoked—whether the insured knew or should have known that death or injury was common, natural, or substantially likely—precludes coverage even if, on the particular occasion, the insured may not have realized he or she was injecting a lethal overdose. This standard is adopted from, and is consistent with, the principles repeatedly employed by California appellate decisions in analyzing diverse factual contexts involving insurance coverage claims in nondrug cases. (See, e.g., Cox v. Prudential Ins. Co., supra, 172 Cal.App.2d 629, 635-636; Rooney v . Mutual Benefit H. & A. Assn., supra, 74 Cal.App.2d 885, 890; Davilla v. Liberty Life Ins. Co., supra, 114 Cal.App. 308, 316; Horton v. Travelers Ins. Co., supra, 45 Cal.App. 462, 473-474 [emphasizing the distinction between a voluntary act and a voluntary exposure to a known danger].)
In other jurisdictions, a similar analysis has developed. In Lloyd v. First Farwest Life Ins. Co. (1989) 54 Wn.App. 299 [773 P.2d. 426, 427], the court held that a policy providing coverage for bodily injury caused by accident [146]*146did not afford coverage for a ruptured cerebral aneurysm resulting from the insured’s deliberate, nonmedical inhalation of cocaine. (Id., 773 P.2d at p. 429.) Without indicating whether the claimant personally had been aware of the risks, the court concluded it was not necessary that the claimant intend or expect the injurious consequences of her actions; rather, all that was required, in order for coverage to be precluded, was proof that the claimant knew or should have known “facts from which a prudent person would conclude that the injurious consequences are reasonably forseeable.” (Id., 773 P.2d at p. 428; see also Whiteside v. New York Life Ins. Co. (1972) 7 Wn.App. 790 [503 P.2d 1107, 1109-1110] [insured, who had a long history of drug use and died by self-injecting an overdose of methedrine and morphine, held not to have died by accidental means—which the court held are not present when a deliberate act is performed, unless an additional independent and unforeseen event intervenes].)
Similarly, in Jackson v. National Life & Accident Insurance Co. (1973) 130 Ga. App. 208 [202 S.E.2d 711,712], the court held that the insured, who had died by means of an injection of a “massive dose” of heroin and whose body contained needlemarks indicating prior heroin use, did not die by “accidental means” within the coverage of the policy. (202 S.E.2d at pp. 712-713.) The court noted that, in view of the circumstances involved in heroin use, which include the use of unsterilized needles and utensils, often in unsanitary locales, as well as the inability of the user to determine the strength or purity of a given dosage, “death is a common experience and the user may reasonably expect it.” (202 S.E.2d at p. 712.) The court concluded that a lethal injection by such a user is not an unforeseen, unexpected, unusual, or unintentional act, and therefore the injury did not result from “accidental means.” (Ibid.)
In Gordon v. Metropolitan Life Insurance Company (1970) 256 Md. 320 [260 A.2d 338, 41 A.L.R.3d 648], the court concluded the insured did not die by “accidental means,” based upon the circumstances that (1) the insured had a history of narcotics addiction and died by self-administering heroin as well as an excessive dose of Doriden, a sedative, (2) there was no claim a mishap had occurred in the act of injection, and (3) evidence was presented that narcotics users are aware of the substantial risk involved in self-administering heroin. (260 A.2d at pp. 338-341.) Noting the probability that the combination of heroin and Doriden caused the fatality, the court observed that the possibility the decedent may have been unaware of the risk in taking that combination of drugs was irrelevant, because heroin by itself carried a “well known and substantial risk.” (260 A.2d at p. 339.) The court also observed that, although in some cases there may not be any way to distinguish “accidental means” from “accidental results,” in a case where an [147]*147insured intentionally administers an illegal substance that possesses a “serious foreseeable risk,” the distinction is clear and death cannot be said to have occurred by “accidental means.” (260 A.2d at p. 340; see also Prudential Ins. Co. of America v. Gutowski (1955) 49 Del. 233 [113 A.2d 579, 585-586, 52 A.L.R.2d 1073] [the trial court erred in submitting to the jury the issue whether death occurred by “accidental means,” because the evidence indicated the insured died after ingesting voluntarily—and without mishap—a large overdose of barbiturates].)8
Although a number of decisions have held otherwise, there appears to be a developing tendency, which we now endorse, expressed in the Hargreaves case (Hargreaves v. Metropolitan Life Ins. Co., supra, 104 Cal.App.3d 701) from our own jurisdiction and in decisions from other jurisdictions, for courts to conclude that a fatal reaction to the voluntary, deliberate, and “nonmedical” taking of an illegal substance, without mishap, should not be considered death by “accidental means,” even when the insured may not have had personal knowledge that death was common, natural, or substantially likely as the result of ingesting the amount actually taken. It is readily [148]*148apparent that the risks attending the consumption of such substances are so great that death must be considered a common, natural or substantially likely consequence. As suggested by the dissent in the Court of Appeal in the present case, because the user may not be certain of the purity or strength of a particular dosage of an illegal substance, the possibility of overdose is a closely related consequence of ingestion, inhalation, or injection, and the circumstance of the overdose itself does not operate as an independent or intervening means of death in the sequence of causation from the initial voluntary act to the death resulting from it. Therefore, the insured is not entitled to coverage for such a death under an “accidental means” policy, because he or she should know that death is a common, natural, or substantially likely result of such activity.
V
Having concluded there was double indemnity coverage in the present case only if death was caused by an accident unrelated to the insured’s voluntary ingestion of cocaine, we now consider whether plaintiffs are entitled to summary judgment based upon that theory or instead there remains a triable issue of material fact upon that issue.
The burden is upon the plaintiffs to establish that the occurrence forming the basis of their claim is within the basic scope of insurance coverage. (Royal Globe Ins. Co. v. Whittaker (1986) 181 Cal.App.3d 532, 537 [226 Cal.Rptr. 435]; see Garvey v. State Farm Fire & Casualty Co. (1989) 48 Cal.3d 395, 406 [257 Cal.Rptr. 292, 770 P.2d 704]; Clemmer v. Hartford Ins. (1978) 22 Cal.3d 865, 880 [151 Cal.Rptr. 285, 587 P.2d 1098].) Therefore, plaintiffs bore the burden of establishing that the death of the insured was caused by an accident unrelated to his voluntary ingestion of cocaine. (Ells v. Order of United etc. Travelers (1942) 20 Cal.2d 290, 304 [125 P.2d 457]; Rock v. Travelers’ Insurance Co., supra, 172 Cal. 462, 464; see Zuckerman v. Underwriters at Lloyd’s, supra, 42 Cal.2d 460, 472-473.
Plaintiffs attempted to establish that the drug Darvocet caused or contributed to Mr. Weil’s death, offering evidence that, several weeks prior to his death, that particular drug had been prescribed for Mr. Weil, and the day before his death he had informed his mother he was taking the drug. This evidence is not uncontroverted, however. The chemical analysis of bodily tissues furnished by defendant demonstrates that no trace of Darvocet was detected in Mr. Weil’s system, even though, as metabolized in the body, its half-life is of sufficient duration to have rendered its presence detectable at the time the analysis was performed. The only substance that appeared in his system in a lethal quantity was cocaine.
[149]*149Plaintiffs also attempted to demonstrate that, even if Mr. Weil’s death was caused by ingestion of a lethal overdose of cocaine, that occurrence was not the result of his own voluntary act in taking the drug, but resulted from unknown external forces. In support of this claim, plaintiffs rely upon the circumstances that, at the time of Mr. Weil’s death, he was in the company of a prostitute, that the person who identified Mr. Weil’s body and claimed to know him was unknown to his family and business associates and subsequently could not be located by the police, and that Mr. Weil’s condominium, located in another city, was burglarized sometime during the weekend Mr. Weil expired in San Francisco.
Plaintiffs’ evidence is controverted by the report of the coroner’s investigators’ conversation with the prostitute who had been summoned to Mr. Weil’s hotel room approximately two hours prior to his death.9 She told the investigators that, upon meeting Mr. Weil at the door, she noticed he appeared intoxicated, prompting her query whether he was under the influence of drugs, to which he responded he “would be all right.” She reported that some time later, Mr. Weil left the bedroom and entered the bathroom, where she observed him place a white powder in his mouth from a blue dish in the sink. She also reported that Mr. Weil soon began to experience shortness of breath, causing her to be fearful and to leave. She did not state that anyone else was in the room prior to her departure.
This evidence, considered with proof that a substantial amount of cocaine was present in Mr. Weil’s system, that a sample (presumably taken from the blue dish) tested positive for cocaine, and that there was no external or internal trauma to the body (except those consistent with an overdose of cocaine), precludes any conclusive finding that Mr. Weil’s death resulted solely from external means or from any agency other than his own voluntary and intentional ingestion of a substantial quantity of cocaine. Accordingly, plaintiffs are not entitled to summary judgment on the theory that death occurred by “accidental means.”
[150]*150VI
Decisions of this court and the Courts of Appeal have not extended coverage, under policies covering death by “accidental means,” to those situations in which the nature of the insured’s voluntary act is such that he or she reasonably could anticipate that death or great bodily harm is a common, natural, or substantially likely consequence, and a number of decisions in various jurisdictions expressly have disallowed coverage, under policies similar to the present one, for the deliberate, intentional ingestion of illegal substances that an insured knows, or should know, involve a substantial likelihood of death. Accordingly, we conclude the superior court erred in determining that the insured’s death, arising from a voluntary and intentional act that resulted in an unintentional overdose of cocaine, was caused by “accidental means” within the meaning of the insurance policy. For the foregoing reasons, we reverse the judgment of the Court of Appeal and direct that court to remand this action to the trial court.
Lucas, C. J., Panelli, J., Arabian, J., and Baxter, J., concurred.