Mrs. Amelia Bryant v. Continental Casualty Company

Summary

The Texas Supreme Court reversed the lower courts, holding that death by sunstroke incurred while the insured was walking in the ordinary course of his occupation is covered under the accident insurance policy because sunstroke is a form of bodily injury caused by external, violent and accidental means in the popular sense. The court interpreted the policy’s special provision to include sunstroke as an accident despite the insured’s voluntary exposure to the sun.