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.

The Dixon Divide

Finney argued that MetLife denied benefits without investigating whether illness substantially contributed to Anderson’s death, unlike in Dixon. But MetLife countered that such an inquiry wasn’t required. Its February appellate brief said federal workers’ coverage is even tighter, paying only when death arises from “violent, external and accidental means” independent of all other causes.

Judge Maze had already ruled in 2024 that, under either Dixon’s test or the strict contract wording, the denial stood.

Tough Questions from the Bench

Judge Andrew L. Brasher pressed MetLife’s counsel, Scott Burnett Smith, on how sweeping the exclusions were: “It seems like the exclusion is actually a little bit broader in taking things away than coverage.”

Judge Britt Grant followed up, bluntly remarking, “Honestly, I would not sign up for this coverage, given how limited it appears to be. But that exclusion … rings pretty true here, at least to me.”

Despite recognizing the policy’s narrowness, both judges implied that its language left little space for reversal.

Stakes Beyond One Family

Finney’s fight touches thousands of federal employees whose accidental death protections may be far less reliable than they believe. For families, the FEGLIA policy can feel like a parachute riddled with holes—appearing to promise safety but collapsing when illness is a factor.

Representation

Finney is represented by Clay Williams of The Martin Law Group LLC.
MetLife is represented by Scott Burnett Smith, Schyler B. Burney, and T. Matthew Miller of Bradley Arant Boult Cummings LLP.

Judges Robin S. Rosenbaum, Britt C. Grant, and Andrew L. Brasher presided over the Eleventh Circuit hearing.