INSURANCE-RELATED COURT CASES
Digested from case reports published online
COURT DECISIONS
Death, but not an accident
Selina Anderson, a federal government employee, met with tragedy while she was under the protection of a group life insurance policy issued by Metropolitan Life Insurance Company (MetLife). While exiting a car onto an athletic field’s parking lot, she fell and was injured. It turned out that her leg had been broken in two places. She was transported to an emergency room, where surgery was performed. A chronic smoker with a history of lung disease, Selina’s body couldn’t handle the stress from the surgery. A blood clot lodged in her lung and, unfortunately, a week after the operation she died.
Her daughter, Brittany Finney (Finney), was Selina Anderson’s beneficiary at the time of her accident and passing. When attempting to secure life insurance proceeds as well as an accidental death benefit from the insurer, the accidental death portion was denied. Finney sued for full coverage and after a lower court ruled in favor of MetLife, she appealed.
The higher court reviewed the dispute afresh. As a federal employee, Selina Anderson’s life insurance was arranged via the Federal Employees’ Group Life Insurance (FEGLI) Act. The Act permits its administrators to buy private insurance coverage from carriers such as MetLife. It also provided both group life as well as accidental death and dismemberment (AD&D) protection. Both coverages were sold to Selina Anderson with Finney as the beneficiary.
MetLife paid Finney the $57,000 it owed her for the life insurance policy portion but withheld the $57,000 limit that was possible under its AD&D policy. The insurer shared the following reasons: One was that the death did not qualify as it was not caused by directly suffering violent, external, accidental bodily injury. Two, the death appeared to stem from chronic lung disease and that was subject to an exclusion against illnesses. These arguments persuaded the lower court to rule in favor of MetLife.
The higher court examined both of the insurer’s arguments. Like the lower court, it did not accept the first item out-of-hand. Rather, it reasoned that the insurer did not adhere to the policy language when determining what part of the loss was accidental. The court focused on the following wording:
“Accidental Death and Dismemberment benefits shall be paid when an eligible Employee sustains bodily injuries solely [emphasis, ours] through violent, external, and accidental means …”
It pointed out that MetLife’s first argument was that the leg injury suffered by Selina Anderson was not the sole reason for her death. The court’s opinion was that their interpretation was irrelevant. What the above wording requires is that any bodily injury results violently, externally and accidentally. By any measure, the broken leg met the wording’s requirements.
However, the important point was that MetLife’s second argument rendered moot any ambiguity in its first. In that part, the AD&D policy wording clearly states that only deaths that result directly from accidental injury are eligible for coverage. The policy excludes instances when death involves a contributing factor.
Both the lower and the higher courts agreed that Selina Anderson initially suffered a serious accident. However, after surgery was performed, her recovery failed due to her medical problems involving lung disease as well as chronic obstructive pulmonary. These medical issues both acted to increase her vulnerability, which resulted in her death. Therefore, the loss was excluded from receiving payment under the AD&D policy. The lower court decision in favor of MetLife was affirmed.
Brittany Finney v. Metropolitan Life Insurance Company—U.S. Court of Appeals for the 11th Circuit—No. 24-13140—January 26, 2026.
