New York Clarifies Presumption Against Suicide
In Green v. William Penn Life Ins. Co. of NY, the court reviewed New York’s presumption against suicide, clarifying that decisional law and New York’s Pattern Jury instruction merely articulate guides for finders of fact, not rules of law that compel dismissal of claims as a matter of law.
In this case, a claim for life insurance was rejected on the basis that the insured committed suicide. After a non-jury trial, the court found that the insured had committed suicide and dismissed the complaint. Evidence at trial supported a finding that the insured committed suicide, but there was also evidence that suicide was not the cause of death. In a 3-2 decision, an appellate court reversed, holding that “the evidence failed as a matter of law to overcome the presumption against suicide.” The appellate court reasoned that because “there are other reasonable conclusions that may be drawn from the evidence, aside from suicide," the "application of the law regarding the presumption against suicide necessitated a directed verdict in this case.”
New York’s high court reversed, holding that the presumption against suicide, which “springs from strong policy considerations as well as embodying natural probability,” is not a rule that requires rejection of suicide as a matter of law, but is merely a guide for the fact finder. ... Where the evidence leaves open two possible findings, it is the jury's business to resolve the doubt.”
The court clarified the New York Pattern Jury Instructions, which state: "You may make a finding of suicide only if you are satisfied from the evidence, and taking into consideration the presumption against suicide, that no conclusion other than suicide may reasonably be drawn.” “This language,” held the court, “should not be taken to mean that, where more than one conclusion is reasonably possible, suicide is excluded as a matter of law.” Instead, the instruction “is directed at jurors deciding facts, not at judges deciding the law; it is a way of impressing on jurors' minds that the presumption against suicide is a strong one—of telling them they should not find suicide unless the evidence shows suicide to be highly probable.”
Thus, because there was evidence legally sufficient to support the trial court’s decision, the appellate court was found in error for rejecting the finding of suicide as a matter of law.
