Brittany Finney v. Metropolitan Life Insurance Company
Opinion
FOR PUBLICATION
In the United States Court of Appeals For the Eleventh Circuit
No. 24-13140
BRITTANY FINNEY, Plaintiff-Appellant, versus
METROPOLITAN LIFE INSURANCE COMPANY, Defendant-Appellee.
Appeal from the United States District Court for the Northern District of Alabama D.C. Docket No. 1:22-cv-01046-CLM
Before ROSENBAUM, GRANT, and BRASHER, Circuit Judges. GRANT, Circuit Judge:
Selina Anderson did not expect her life to end shortly after she broke her leg from tripping and falling in a parking lot, but years of chronic disease had left her vulnerable. The stress of
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surgery was too much for her body to overcome, and she passed away less than a week after the accident. Anderson’s daughter filed a claim for accidental death benefits, but the insurance company denied it, citing a policy exclusion that bars payment when the insured’s “physical or mental illness” “contributed to” a death. Because that decision was not arbitrary or capricious, we affirm.
I.
Selina Anderson fell while getting out of a vehicle in an athletic field parking lot. She was rushed to the emergency room, where her knee appeared “[m]arkedly swollen and deformed.” X-rays revealed that her leg was broken in two places. Orthopedic surgery soon followed, but things went from bad to worse when her body could not handle the stress of surgery. A blood clot lodged in her lung, wreaking havoc on her lung tissue. Pneumonia, diffuse alveolar damage, and bilateral subpleural fibrosis followed. Essentially, Anderson’s lungs were shutting down, and she died a few days later. Her autopsy report listed her cause of death as “pulmonary embolism”—the blood clot. While concluding that her leg fractures “were likely responsible for the final event,” the autopsy also emphasized her history of “underlying interstitial lung disease.” A chronic smoker, Anderson had long struggled with lung disease and other serious health issues. In fact, she needed steroids and home oxygen therapy to get by in her daily life.
This sad series of events ended up in federal court because Anderson worked for the federal government and had a life insurance policy through the Federal Employees’ Group Life
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Insurance Act of 1954 (FEGLI). See 5 U.S.C. § 8701 et seq. By statute, the Office of Personnel Management administers FEGLI, and may “prescribe regulations necessary to carry out” its purposes. Id. § 8716(a). OPM may also purchase insurance policies from private companies like MetLife. Id. § 8709(a). Those companies are then in charge of approving and denying individual claims. And when there is a dispute, the claimant may sue the insurer for breach of contract. See 5 C.F.R. § 870.102 (1997).
FEGLI offers two types of policies: “group life insurance”
and “accidental death and dismemberment insurance.” 5 U.S.C. § 8709(a). Life insurance is the more familiar concept—if the insured dies while the policy is in force, a beneficiary receives payment from the insurer. Though less common, accidental death insurance is what it sounds like—if the insured dies from an accident, the insurer will pay extra benefits, separate and apart from the standard life insurance payment.
Like countless other federal employees, Anderson signed up for group life insurance. With important caveats, MetLife promised to pay her beneficiary, Brittany Finney, $57,000 in the event of Anderson’s death and another $57,000 if her death was accidental. After Finney, Anderson’s daughter, filed both claims with MetLife, she received a check for $57,000—half of what she requested. MetLife’s denial letter offered two independent reasons. First, it said Anderson’s death was not “accidental” because it did not result “directly” from “a bodily injury caused solely through violent, external, and accidental means.” Second, MetLife said
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Anderson’s “known history” of chronic lung disease “contributed to” her death, triggering a separate physical illness exclusion.
Finney sued, claiming that MetLife’s denial breached the insurance contract. Because the case involved no factual disputes, both sides filed motions for judgment as a matter of law. See Fed. R. Civ. P. 50(a)(2). The district court ruled for MetLife, concluding that MetLife reasonably denied Finney’s claim under the policy’s physical illness exclusion. This is Finney’s appeal.
II.
We review de novo a district court’s order granting a party’s motion for judgment as a matter of law. Abel v. Dubberly, 210 F.3d 1334, 1337 (11th Cir. 2000).
III.
Under Anderson’s FEGLI policy, MetLife has discretion to decide whether claimants are entitled to benefits. Even if we were skeptical about MetLife’s conclusion that Anderson’s death fell outside the scope of the policy’s coverage provision, we agree with the district court that MetLife reasonably invoked the policy’s physical illness exclusion to deny Finney’s claim.
A.
An insurance policy is a contract—a bargain between the insurer and the insured. And “the contract itself ” is “the measure of the insurer’s liability.” 1B John A. Appleman & Jean Appleman, Insurance Law and Practice § 391 (1981). We construe insurance contracts like any other: “by their terms and consistent with the
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intent of the parties.” CITGO Asphalt Refin. Co. v. Frescati Shipping Co., 589 U.S. 348, 355 (2020) (quotation omitted). In doing so, we give effect to the “clear and unambiguous” meaning of the words used. Id. (quotation omitted); see Restatement (Second) of Contracts § 203(b) (A.L.I. 1981).
Under Anderson’s insurance policy, MetLife’s decision about a claimant’s entitlement to benefits “is to be given full force and effect, unless it can be shown that the determination was arbitrary and capricious.” If it is, we set it aside. If it’s not, we give it “full force and effect.”
The district court, in contrast, applied the (unique) six-step inquiry that this Court developed for cases involving ERISA benefits decisions. See Blankenship v. Metro. Life Ins. Co., 644 F.3d 1350, 1355 (11th Cir. 2011); Johnson v. Reliance Standard Life Ins. Co., 159 F.4th 1304, 1309–10 (11th Cir. 2025). But we see no reason to import our lengthy and sometimes confusing ERISA framework into FEGLI cases. That’s especially true since the insurance contract itself calls for arbitrary-and-capricious review.
Arbitrary-and-capricious review ultimately boils down to one question: whether the challenged decision is “reasonable and reasonably explained.” FCC v. Prometheus Radio Project, 592 U.S. 414, 423 (2021). But while this standard is “exceedingly deferential,” it is not “toothless.” Florida v. Dep’t of Health & Hum. Servs., 19 F.4th 1271, 1290 (11th Cir. 2021) (quotation omitted); Biden v. Texas, 597 U.S. 785, 816 (2022) (Kavanaugh, J., concurring). A claimant may prevail if the challenged decision “is without reason, unsupported
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by substantial evidence or erroneous as a matter of law.” McLeod v. Hartford Life & Accident Ins. Co., 372 F.3d 618, 623 (3d Cir. 2004) (quotation omitted).
B.
We start, as always, with the text of the policy. The two italicized coverage requirements drive our analysis here:
Accidental Death and Dismemberment benefits shall be paid when an eligible Employee sustains bodily injuries solely through violent, external, and accidental means and not more than one year thereafter suffers any of the losses specified in this Section as a direct result of such bodily injuries, and independently of all other causes.
The policy goes on to catalogue a series of exclusions: “benefits will not be paid if the death or loss in any way results from, is caused by, or is contributed to by” a laundry list of various conditions or events. The first two are relevant here—the insured’s “physical or mental illness” and the “diagnosis of or treatment of ” that illness. Others include nuclear war, suicide, illegal drug use, or drunk driving.
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