Wetzel v. Westinghouse Electric Corp., 393 A.2d 470 (Pa. Super. Ct. 1978):

Willy C. J. Wetzel died on March 16, 1975 at the hand of his son, Roy Wetzel. Roy Wetzel was tried by a jury for murder and voluntary manslaughter . . . and was found not guilty. Mary Margaret Wetzel, appellant and widow of Willy Wetzel, then brought this suit to recover the insurance proceeds from an accidental death policy issued on her husband’s life. At the close of the pleadings, both parties moved for summary judgment, [asking] . . . the court to decide, as a matter of law, whether the death of Willy C. J. Wetzel occurred through "accidental means" within the meaning of the insurance policy on his life.

Willy Wetzel and his son, Roy Wetzel, were experts in the martial arts, including karate, and operated a [martial arts] school…. On the day of Willy Wetzel’s death, Roy had been working on his father’s income tax return. Willy visited his son and began reading the completed tax forms….As Willy Wetzel started to sign the tax forms, he threw the pen against the drapes and began to scream obscenities.  He walked toward the front door mumbling that he was going to lose his house, car and everything. Grabbing a Hawaiian sword, Willy Wetzel turned and let out a battle cry called a "kewah." The fight began.

Willy began to remove the sword from its case when Roy attempted to grab the case. Willy kicked Roy and the sword was bent in half. The hand-to-hand fight continued for approximately twenty-five minutes. Roy made several attempts to reach the telephone to call for help, but was stopped each time by his father’s tactics. Finally, Roy placed nanchukas sticks, used in karate, around his father’s head to try to render him unconscious. Shortly after that Roy realized his father was dead.

Based on these facts, we are faced with deciding whether the death of Willy Wetzel occurred through accidental means under the insurance policy in question….

The facts of the case before us show Willy’s rage was due to his income tax return and was in no way related to the procurement of the accidental insurance policy. Nor would denying recovery to an innocent beneficiary in this case deter this type of culpable conduct on the part of the insured….

In following this reasoning, we find that the death of Willy Wetzel was due to "violent, external and accidental means" within the meaning of the policy, and appellant, as an innocent beneficiary, must recover.

(Thanks to Joel Newman (Wake Forest) for the tip.)