The MetLife Benefits Denial suit landed in the Eleventh Circuit on Thursday, where judges seemed unmoved by an appeal challenging the insurer’s refusal to pay death benefits. The case stems from the death of Selena Anderson, a former Social Security Administration employee who died days after breaking her leg and ankle. Her daughter, Brittany Finney, sought to recover under her late mother’s accidental death and dismemberment policy, but the panel zeroed in on contract language that carved out illness-linked deaths.
Anderson’s policy, administered by MetLife under the Federal Employees’ Group Life Insurance Act (FEGLIA), proved to be a maze of exclusions. She died in a hospital following complications from a pulmonary thromboembolism, according to U.S. District Judge Corey L. Maze, who sided with MetLife in September 2024.
Judges Spotlight Harsh Exclusions
From the start, the three-judge panel highlighted how the FEGLI contract narrowed coverage. The definition of accidental death required that it result “independent of all other causes,” while an exclusion barred benefits if death related in any way to illness, treatment, or diagnosis.
“I sympathize with your client,” Judge Robin S. Rosenbaum told Finney’s lawyer, Clay Williams. “It’s very unfortunate … but we still have to comply with the FEGLI statute. And the FEGLI statute tells us we must comply with the contract.”
Williams invoked the 2004 Dixon v. Life Ins. Co. of N. Am. decision, which required insurers under ERISA to investigate whether illness “substantially contributed” to a death. But Rosenbaum stressed that Dixon applied to private plans, not federal ones governed by FEGLIA.
