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.
