Can mental illness overcome intentional injury exclusions in insurance coverage? Heslop v. Bear River Explained

The Utah Supreme Court’s decision in Heslop v. Bear River Mutual Insurance Company provides crucial guidance for practitioners handling insurance coverage disputes involving mental health issues and intentional injury exclusions.

Background and Facts

Natalie Heslop overdosed on prescription Ambien and Lexapro, then drove her truck off an embankment the following day. She admitted to police, medical personnel, and her insurance adjuster that the crash was “pretty much a suicide attempt.” Bear River Mutual Insurance denied both her personal injury protection claim and her husband’s property damage claim under the policy’s intentional injury exclusion. The Heslops presented expert testimony suggesting that medication-induced serotonin syndrome may have impaired Heslop’s cognitive abilities and decision-making capacity.

Key Legal Issues

The case presented two primary issues: whether mental illness or medication effects can defeat an intentional injury exclusion when the insured admits to intentional conduct, and what standard of evidence is required to create a genuine issue of material fact regarding the insured’s mental capacity.

Court’s Analysis and Holding

The Utah Supreme Court affirmed summary judgment for Bear River, applying the Hoffman test which considers mental illness relevant only when the insured either cannot appreciate the consequences of her conduct or cannot control her conduct despite understanding the consequences. The court found that the expert opinions were too equivocal and speculative to create a genuine factual dispute. Dr. Crookston’s opinion that Heslop “could not fully appreciate” consequences and Dr. Holt’s statement that medication “could be” attributed to “some” irrational behavior failed to provide sufficient foundation for a jury to reasonably infer that Heslop lacked the requisite mental capacity.

Practice Implications

This decision establishes that mental health evidence must be specific and unequivocal to overcome intentional injury exclusions. Practitioners should ensure expert testimony directly addresses the insured’s ability to understand specific consequences and control specific actions, rather than providing general statements about possible impairment. The court’s rejection of the Michigan Miller standard clarifies that Utah law does consider mental illness, but only when supported by concrete evidence rather than speculation.