Garza v. Sun Life Assurance Company of Canada
We achieved a significant victory for Sun Life in the Southern District of Texas, securing summary judgment in an ERISA claim involving Accidental Death & Dismemberment (AD&D) benefits. In Garza v. Sun Life Assurance Company of Canada, the plaintiff sought AD&D benefits following the death of her husband, who suffered an allergic reaction to a wasp sting. At issue was Sun Life’s interpretation and application of a provision in the AD&D policy, excluding benefits for loss caused by disease. After extensive briefing, the court upheld Sun Life’s conclusion that a wasp venom allergy is a “disease” pursuant to the exclusion. The decision also represents a significant victory for defense of future ERISA cases in the Fifth Circuit, in light of the Court’s holding that plaintiff’s primary interpretation argument was barred by her failure to raise it during Sun Life’s administrative claims process, pursuant to ERISA’s exhaustion requirements.