Insured was shot by police officers while attempting to escape in a car which he and his companions had just stolen. The officers had no specific intent to kill, but did intend to make the arrest and were shooting to frighten the felons into stopping. The policy contained no specially exempted risks, but did provide for additional indemnity if the insured died of injuries sustained solely through "external, violent, and accidental means." The face value of the policy was not contested, but the insurer contested the right to the additional sum. Held, the death was not caused by accidental means, and such a recovery would be against public policy. Piotrowski v. Prudential Ins. Co. of America, 252 N. Y. S. 313 (1931).

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