FEGLI Accidental-Death Claims: Contractual Arbitrary-and-Capricious Review Applies, and “Contributed To By” Illness Exclusions Are Enforceable

Introduction

In Brittany Finney v. Metropolitan Life Insurance Company (11th Cir. Jan. 26, 2026), the Eleventh Circuit affirmed the denial of accidental death and dismemberment (“AD&D”) benefits under a life insurance policy issued pursuant to the Federal Employees’ Group Life Insurance Act of 1954 (FEGLI), 5 U.S.C. § 8701 et seq..

The insured, Selina Anderson, a federal employee, died days after a trip-and-fall caused severe leg fractures, surgery followed, and she suffered a fatal pulmonary embolism with cascading pulmonary complications. Her daughter and beneficiary, Brittany Finney, received standard life insurance proceeds but was denied the additional AD&D amount by Metropolitan Life Insurance Company (MetLife).

The dispute centered on two policy features: (1) the scope of AD&D coverage (including “direct result” language) and (2) an exclusion barring payment when death “in any way results from, is caused by, or is contributed to by” the insured’s “physical or mental illness” (or treatment/diagnosis thereof). The core appellate issues were the proper standard of review for a FEGLI benefits denial and whether MetLife reasonably applied the illness exclusion to Anderson’s death.

Summary of the Opinion

The court held that because the FEGLI policy granted MetLife discretionary authority, MetLife’s benefits determination was entitled to arbitrary-and-capricious review as stated in the contract—without importing the Eleventh Circuit’s ERISA-specific, multi-step framework. Applying that deferential standard, the court concluded MetLife reasonably denied AD&D benefits based on the policy’s illness exclusion because Anderson’s extensive lung disease contributed to her death.

Although MetLife also denied coverage on the theory that the death was not “accidental” under the coverage grant, the court expressed skepticism about MetLife’s reading of the “solely” requirement (explaining it modifies how the injury is sustained, not whether death results solely from the injury). The court did not resolve the meaning of “direct result,” because the illness exclusion independently supported denial.

Analysis

Precedents Cited

Abel v. Dubberly, 210 F.3d 1334 (11th Cir. 2000)
Cited for the appellate standard of review: the Eleventh Circuit reviews de novo a district court’s grant of judgment as a matter of law. This procedural anchor mattered because the dispute was framed as purely legal (no material fact disputes).
CITGO Asphalt Refin. Co. v. Frescati Shipping Co., 589 U.S. 348 (2020) and Restatement (Second) of Contracts § 203(b) (A.L.I. 1981)
Used to emphasize orthodox contract interpretation principles: courts enforce the “clear and unambiguous” meaning of policy text and interpret terms consistently with the parties’ intent. This supported the court’s insistence on reading the FEGLI policy’s “solely” and exclusionary language as written rather than reshaping it for perceived fairness.
Blankenship v. Metro. Life Ins. Co., 644 F.3d 1350 (11th Cir. 2011) and Johnson v. Reliance Standard Life Ins. Co., 159 F.4th 1304 (11th Cir. 2025)
These cases supply the Eleventh Circuit’s “unique” six-step framework for reviewing ERISA benefits determinations. The court cited them to explicitly decline to transplant that framework into FEGLI, underscoring that FEGLI disputes should be governed by the contractual standard of review (here, arbitrary-and-capricious) rather than a specialized ERISA methodology.
FCC v. Prometheus Radio Project, 592 U.S. 414 (2021); Florida v. Dep't of Health & Hum. Servs., 19 F.4th 1271 (11th Cir. 2021); and Biden v. Texas, 597 U.S. 785 (2022) (Kavanaugh, J., concurring)
These authorities define the operational content of arbitrary-and-capricious review: the decision must be “reasonable and reasonably explained,” the standard is “exceedingly deferential,” but not “toothless.” The court used them to calibrate the lens through which MetLife’s denial must be judged.
McLeod v. Hartford Life & Accident Ins. Co., 372 F.3d 618 (3d Cir. 2004)
Quoted for a common formulation of when a claimant can win even under deferential review: when the decision is “without reason,” unsupported by substantial evidence, or legally erroneous. The citation bolstered the court’s point that deference still requires evidence-based, lawful decisionmaking.
Dixon v. Life Ins. Co. of N. Am., 389 F.3d 1179 (11th Cir. 2004)
The appellant relied on Dixon to argue that illness-related contributions should not defeat accidental death benefits. The court distinguished Dixon as contract-specific (and ERISA-based), emphasizing that Dixon construed different exclusion language—barring payment “for loss resulting from” illness—whereas this FEGLI policy excludes death that “in any way” is “contributed to by” illness. The court also rejected the suggestion that Dixon created a general federal common law rule for all AD&D policies.
Interline Brands, Inc. v. Chartis Specialty Ins. Co., 749 F.3d 962 (11th Cir. 2014)
Cited in response to the “illusory coverage” argument. Finney contended MetLife’s reading would mean the policy covers nothing. Interline supplied the principle that contracts should not be construed to nullify coverage; the court rejected the illusory-coverage claim because the policy still covers clear accident-only deaths.
1B John A. Appleman & Jean Appleman, Insurance Law and Practice § 391 (1981)
Cited for the foundational insurance rule that “the contract itself” measures the insurer’s liability—reinforcing the court’s unwillingness to rewrite exclusions that the parties accepted.

Legal Reasoning

FEGLI structure and private insurer role.
The opinion situates the dispute within FEGLI’s statutory scheme: the Office of Personnel Management administers FEGLI and may procure group policies from private insurers (5 U.S.C. § 8709(a)), and claimants may sue insurers on the contract when benefits are denied (the court references 5 C.F.R. § 870.102 (1997)). This matters because the case is treated as a contract dispute governed by the policy’s terms (including any agreed standard of review).
Standard of review: contract-based arbitrary-and-capricious, not ERISA’s framework.
The FEGLI policy conferred discretion on MetLife and stated its determination should be given “full force and effect” unless “arbitrary and capricious.” The district court applied the Eleventh Circuit’s ERISA six-step test (from Blankenship v. Metro. Life Ins. Co.), but the panel rejected that approach as unnecessary and potentially confusing in FEGLI cases, especially where the contract itself specifies the standard. The court distilled the operative inquiry to whether the denial was “reasonable and reasonably explained” (drawing on FCC v. Prometheus Radio Project and related authority).
Coverage grant: correcting the “solely” misread; leaving “direct result” unresolved.
MetLife’s first rationale asserted the death was not accidental because it did not result “solely” from the leg injury. The court criticized this as a textual error: “solely” modifies the means of injury (“injuries solely through violent, external, and accidental means”), not the causal chain to death. The more relevant coverage limitation is that death must be a “direct result” of the accidental injury. But the court declined to define “direct result” (but-for vs. proximate cause, etc.) because the exclusion independently resolved the claim.

The court also flagged a regulatory wrinkle: the policy included “independently of all other causes” language, while a regulation defines accidental death as one that “results directly from” such an injury (5 C.F.R. § 870.101 (2010)), and the policy stated it must be construed to comply with OPM regulations. The court suggested that if inconsistent, the regulation would control—though it did not need to decide the point.
Exclusion: “contributed to by” is broad, and substantial comorbidities triggered it.
The decisive reasoning was the illness exclusion’s breadth: benefits are not paid if death “in any way” “results from,” “is caused by,” or “is contributed to by” physical illness or related diagnosis/treatment. MetLife relied on a reviewing physician who concluded—within reasonable medical probability—that Anderson’s significant comorbidities (including interstitial lung disease and chronic obstructive pulmonary disease) contributed to her death. The record showed these were serious, ongoing illnesses (steroid use and home oxygen therapy) that plausibly worsened the embolism’s severity and aggravated pneumonia and other pulmonary deterioration. Under deferential review, that evidentiary foundation made the denial reasonable.
Limiting principle: the court hints at de minimis contributions.
The court acknowledged the exclusion could be abused if applied to trivial links between illness and death. While not deciding the interpretive line, it suggested the exclusion “may well” not apply when an illness plays only a de minimis role—signaling that reasonableness review still polices overreach. But it concluded this case was not close given the extensive lung disease.

Impact

FEGLI review will track the policy’s discretionary clause (arbitrary-and-capricious), not ERISA’s multi-step doctrine.
The opinion’s most important institutional move is methodological: it discourages courts and litigants from reflexively using ERISA’s specialized framework in FEGLI contract cases, instead applying straightforward arbitrary-and-capricious review as defined by general administrative-law-like reasonableness principles.
“Contributed to by” exclusions are potent in AD&D disputes involving comorbidities.
Where a policy excludes death “contributed to by” illness, insurers can defeat AD&D claims even when an accident initiates the chain of events—so long as medical evidence supports that substantial preexisting disease meaningfully contributed to death.
Textual precision in coverage clauses matters (and insurer denial letters may be vulnerable on coverage reasoning even if an exclusion saves the result).
The court openly criticized MetLife’s reading of “solely,” a reminder that insurers must match denial rationales to policy grammar and structure. Future litigants may leverage similar textual errors—particularly where no exclusion clearly applies.
A potential future battleground: defining “direct result” and reconciling policy language with OPM regulations.
The panel left open how to interpret “direct result” and how to treat discrepancies between “independently of all other causes” policy language and the regulatory definition in 5 C.F.R. § 870.101 (2010). Those issues are likely to reappear where illness exclusions are absent or contested.

Complex Concepts Simplified

FEGLI: A federal statutory program providing group life insurance (and optional AD&D coverage) for federal employees. OPM oversees the program, but private insurers administer claims under purchased policies.
AD&D (Accidental Death and Dismemberment): An extra benefit paid only if death (or certain injuries) results from an accident as defined by the policy, often subject to exclusions.
Arbitrary-and-capricious review: A deferential standard: the court does not decide the claim fresh; it asks whether the insurer’s decision was reasonable, evidence-based, and legally permissible. A decision can still be overturned if it lacks reason, substantial evidence, or is contrary to law.
Coverage provision vs. exclusion: Coverage provisions define what is included; exclusions carve out situations where benefits will not be paid even if the event otherwise looks covered. In this case, the exclusion (illness “contributed to” death) did the dispositive work.
“Contributed to by”: Broader than “caused by.” It can apply when illness is not the sole cause but materially plays a role alongside accidental injury. The court suggested (without deciding) that merely trivial or de minimis contributions may not justify invoking the exclusion.

Conclusion

Finney v. Metropolitan Life Insurance Company clarifies that FEGLI benefit disputes should be reviewed under the standard the FEGLI policy itself supplies—here, arbitrary-and-capricious—rather than the Eleventh Circuit’s ERISA-specific framework. Applying that deferential review, the court enforced a broadly worded illness exclusion that bars AD&D benefits where physical illness “in any way” “contributed to” death, and found it reasonable to deny benefits given substantial evidence that serious lung disease materially worsened the fatal cascade.

The decision’s broader significance lies in its dual message: FEGLI litigation is fundamentally contract-centered (including as to review standards), and “contributed to by” exclusions can decisively limit AD&D recovery in cases where accidents interact with significant preexisting conditions.