Kunin v. Benefit Life Insurance Co.

Daniel Kunin (plaintiff) incurred over $50,000 in medical bills for treatment of his child’s autism. Benefit Trust Life Insurance Company (Benefit) (defendant) provided a health-insurance policy to Kunin through Kunin’s employer. The policy was an employee-welfare benefit plan governed by the Employee Retirement Income Security Act (ERISA). After Kunin submitted a claim, Benefit agreed to reimburse Kunin for only $10,000, stating that autism fell under the policy’s limit on coverage for mental illness. The policy did not define or explain the term “mental illness” and did not provide any examples of conditions that the term included or excluded. Kunin filed suit in state court, challenging Benefit’s interpretation of the policy. The matter was removed to federal district court on the basis of federal jurisdiction over ERISA. The district court relied on expert testimony to determine the ordinary meaning of the term “mental illness.” Kunin’s experts testified (1) that mental illness referred to a behavioral disturbance with no demonstrably physical basis, arising from reaction to environmental conditions rather than organic causes; (2) that autism would clearly fall outside these criteria for mental illness; and (3) that autism was not a mental illness in the lay or technical senses. The district court concluded that autism was not a mental illness and ordered Benefit to pay Kunin’s claim in full. Benefit appealed.