because mental illnesses are categorized according to either their origins or symptoms, each party presented reasonable interpretations of the mental illness limitation where the policy was silent as to the proper classification. Accordingly, the district court held that the limitation is ambiguous, and applying the applicable state law doctrine of contra proferentem by construing the limitation against the drafter, it held that organically based illnesses do not fall within the limitation. As set out above, our sister circuits have reached differing conclusions regarding the ambiguity of a mental illness limitation that fails to provide whether an illness is classified as mental based on its origin or symptoms. Compare Patterson v. Hughes Aircraft Co., 11 F.3d 948, 950 (9th Cir.1993) (<HOLDING>), and Phillips v. Lincoln Nat’l Life Ins. Co.,
holding that a mental illness limitation containing the exact language at issue in this case is ambiguous because it does not specify whether a disability is to be classified as mental by looking to the cause of the disability or to its symptoms and thus construed in favor of the insured does not encompass organically based illnesses holding that an insurance contract should be construed as a reasonable person in the position of the insured would have understood it and that if the language used in the policy is reasonably susceptible to different constructions it must be given the construction most favorable to the insured holding that the workers compensation act is to be liberally construed in the employees favor and any doubt in its construction is thus resolved in favor of the employee holding that ambiguous agreement between attorney and client must be construed in the clients favor holding that criminal statutes of limitation should be construed in favor of the accused