Insurance Law Commons^™

Insurance - Sunstroke As "Accidental Means"

Michigan Law Review

Insured died as a result of sunstroke suffered while playing golf. Held, Justice Cardozo dissenting, that the beneficiary could not recover because sunstroke was not an "accidental means" within a policy insuring against "death from bodily injuries effected directly and independently of all other causes through external, violent, and accidental means." Landress v. Phoenix Mutual Life Ins. Co., 291 U. S. 491, 54 Sup. Ct. 461, 90 A. L. R. 1382 (1934).