Melvin v. Yale Industrial Products, Inc., 197 F.3d 944 (8^th Cir. 1999)-Melvin, a self-employed farmer and crop-duster, sustained injuries after crashing his small plane while spraying chemicals on his son’s field. His health insurance provider denied coverage on the basis that Melvin’s physical damages fell outside the plan’s definition of “injury” as “non-occupational.”  This court affirmed the district court’s summary judgment against Melvin. This court reviewed de novo, since the ERISA plan did not give the administrator discretionary authority to construe the plan’s terms.  Melvin argued that because the crash occurred while Melvin was dusting his son’s field gratuitously (to use up extra chemicals at the end of the day), he was not practicing his occupation at the time of the crash. Giving the term “occupational” its “common and ordinary meaning,” this court denied that the term was ambiguous.  The court pointed out that doctors and lawyers who work pro bono would be still commonly understood to be practicing their occupation.