In a case stemming from a death in Martin County, Florida, a federal appeals court Wednesday said life-insurance policies excluded coverage for “suicide-by-cop.”
A three-judge panel of the 11th U.S. Circuit Court of Appeals said two policies on the life of Justin Caldwell excluded coverage for suicides.
It said Caldwell, in October 2020, began showing signs of suicidal intent after finding out that his wife wanted a divorce. His wife called authorities, and Caldwell ultimately was shot by police after he pointed a rifle at officers.
News media reports at the time said Caldwell was shot by the Martin County Sheriff’s Office SWAT team. After the beneficiaries of the insurance policies claimed the death benefits, North American Company for Life and Health Insurance went to federal court and argued that it was not required to pay because Caldwell committed suicide.
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A district judge rejected the company’s arguments, but the appeals court Wednesday overturned that decision.
“According to the beneficiaries’ argument, the method matters in that a person commits suicide only when he dies by his own hand,” said the 10-page decision, written by appeals-court Chief Judge William Pryor and joined by Judges Robin Rosenbaum and Stanley Marcus. “North American favors a broader definition that includes a person’s act when he intends to die and achieves that end. We agree with North American. A death is a suicide when a person intentionally causes his own death.”