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(57)

Burn v. Comm.Trav. Mut. Acc.Ins. of Amer. (1946)

die as result of "accidental means"

Death in a snowstorm. Heart condition to
go along w/ it. Run off rd. by other
car — died shoveling snow to get out.

Held: ID may recover.
(sleeping!)

Cause v. effect — minority view. Rejected
here.

TORT v. INS

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