This is an action arising under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. § 1001 et seq. The plaintiff, Ms. Julia E. Craighill, claims entitlement to $525,000 in Broad Business Trip Coverage benefits as beneficiary of a policy of insurance issued by defendant Continental Casualty Company (Continental) to RTKL Associates, Inc. (RTKL), the former employer of Ms. Craighill's deceased husband.*fn1 Ms. Craighill claims that her husband was killed while on a business trip for RTKL and, therefore, benefits are payable under the policy. RTKL claims that it is not liable for payment of the benefits because Continental has the sole obligation to pay benefits that become due under the terms of the policy. Continental in turn claims that Ms. Craighill's husband was killed while traveling from work to home and, therefore, benefits are not payable.
Having fully reviewed the briefs of the parties and the entire record herein, the Court finds that Continental properly denied Ms. Craighill's application for benefits under the Broad Business Trip Coverage plan and has not violated ERISA. The Court grants Continental's motion for summary judgment and denies Ms. Craighill's cross motion for summary judgment. In addition, the Court finds that RTKL has no obligation to pay benefits because Continental has the sole authority to administer the claims process and determine benefits eligibility. The Court therefore grants RTKL's motion for summary judgment and denies Ms. Craighill's motion for summary judgment.
The decedent, Sornratana Goodluck Tembunkiart, was a Vice President of RTKL and worked in RTKL's Washington, D.C., office.*fn2 On Sunday, September 20, 1998, Mr. Tembunkiart drove from his Chevy Chase residence to RTKL's Washington, D.C. office. After working quite late into the evening, Mr. Tembunkiart left work to drive home. At approximately 12:05 a.m. on September 21, 1998, while en route to his home, Mr. Tembunkiart was involved in a vehicular collision and died shortly thereafter.*fn3 Mr. Tembunkiart was 44 years old at the time of his death.
As an officer of RTKL, Mr. Tembunkiart was covered by policy number SR-83106275 ("Policy") issued by Continental to RTKL with a term beginning May 1, 1998 and ending May 1, 1999. Under the Policy, Continental has the sole authority to administer the claims process and determine whether benefits are payable. In the event a covered loss results in death of an insured person aged 69 or younger, and all other terms of the Policy are met, $500,000 becomes payable to the insured person's beneficiary. Mr. Tembunkiart had designated Ms. Craighill as his beneficiary.
The Policy provided Broad Business Trip Coverage, described as follows:
This Description of Hazards covers the Insured Person for injury sustained while on a business trip made on behalf of the Holder (excluding vacations and travel to and from work).
The trip shall begin when the Insured Person leaves his residence or regular place of employment, whichever last occurs, for the purpose of going on the business trip. Such trip shall end on the first of the following to occur:
1. when the Insured Person returns to his residence; or
2. when the Insured Person returns to his regular place of employment.
Coverage provided under this Description of Hazards includes riding as a passenger in any aircraft being used for the transportation of passengers, subject to the EXCLUSIONS below.
The term 'on a business trip made on behalf of the Holder' as used in this Description of Hazards means travel and sojourn authorized by or at the direction of the Holder for the purpose of furthering the business of the Holder.
The Policy also provides that payments will be made only after Continental receives "due written proof of loss."
By letter dated October 6, 1998, RTKL sent Continental various documents in connection with Ms. Craighill's claim for benefits under the Policy. These included a Claimant's Statement for Accidental Death signed by Ms. Craighill on October 4, 1998. In response to the question, "What was the deceased doing at the time of the accident?" Ms. Craighill ...