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Sigler v. Mutual Benefit Life Ins. Co – Case Brief Summary (Federal Court)

In Sigler v. Mutual Benefit Life Ins. Co., 506 F. Supp. 542 (S.D. Iowa), aff'd., 663 F.2d 49 (8th Cir. 1981) (per curiam), the court, applying Iowa law, held that the insured's death from autoerotic asphyxiation was not the result of an accident, id. at 545, because "a reasonable person would comprehend and foresee that placing a noose around his neck and subsequently hanging himself with the noose for the purpose of inducing asphyxia could result in his death." Id. at 544.

Although the insured "did not intend to cause his own death," id., "he reasonably should have expected that his actions could be fatal." Id.

Alternatively, the court concluded that death was due to an intentional self-inflicted injury. It reasoned, at 506 F. Supp. at 545: