Houchens v. American Home Assurance Co.
United States Court of Appeals for the Fourth Circuit
927 F.2d 163 (4th Cir. 1991)
After her husband Coulter disappeared during a trip to Thailand and was declared legally dead, Houchens (plaintiff) sued American Home Assurance (defendant) to collect on accidental-death insurance policies, but the insurer refused to pay because the policies required an accidental death and no evidence showed how or why Coulter died. American moved for summary judgment, arguing Houchens could not establish the accidental-death element essential to her claim.
Whether summary judgment is properly granted against a party who, after adequate discovery, fails to establish a genuine issue of material fact on an element essential to her claim and on which she bears the burden of proof.