The courts of this state have long been vexed with the question of what constitutes an “accident.” As recognized by the Court of Appeals more than 50 years ago, “No all-inclusive definition of ‘accident’ is possible, nor any formulation of a test applicable in every case, for the word has been employed in a number of senses and given varying meanings depending on the relevant context.”1 The recent decision by the Court of Appeals in State Farm Mut. Auto. Ins. Co. v. Langan,2 in the context of uninsured/underinsured motorist insurance, has, quite unexpectedly, overturned the commonly accepted view on how the term “accident” is to be interpreted in that particular area of the law. After briefly placing it in historical and philosophical context, we will analyze this important recent decision below.
Historical Context
In 1918, in Lewis v. Ocean Accident & Guarantee Corp., Ltd. of London, England,3 the Court of Appeals held that the estate of an individual who died from a brain inflammation produced from a germ that came from an infected pimple on his lip, which was punctured by some instrument, was entitled to benefits under a policy that insured against “loss or disability, resulting directly, independently, and exclusively of all other causes, from bodily injuries effected solely through accidental means.”
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