Supreme Court Rules on Suicidal Intent

Court analyzes centuries of insurance law to hand down insured-friendly decision

Most life insurance policies contain a provision under which they won’t pay out death benefits for an insured who commits suicide. These provisions often specifically exclude coverage for suicide committed “while sane or insane.” The Colorado Supreme Court determined that an exclusion with this wording only applies if the decedent intended to kill his or herself. Using this determination, courts might require insurers to prove intent in order to deny life insurance benefits under their “sane or insane” language.

On June 4, the state supreme court answered a certified question from a lawsuit filed in Colorado federal district court. In Renfandt v. New York Life Insurance Company, a woman is suing her late husband’s life insurance company after it denied her claim based on its suicide exclusion. One night Melissa Renfandt’s husband, Mark, was severely intoxicated from a combination of alcohol, prescription medication and marijuana edibles when he shot himself in the head and died.

The plaintiff’s husband had a temporary coverage agreement with New York Life. Renfandt argues that the insurance company should pay the benefits under the policy despite its exclusion for “suicide … while sane or insane” because her husband was too intoxicated to form suicidal intent when he shot himself, therefore his death should be considered accidental.

To read this story and other complete articles featured in the June 11, 2018 print edition of Law Week Colorado, copies are available for purchase online.