Eighth Circuit Affirms AD&D Denial Where Anticoagulant “Contributed To” Fatal Subdural Hematoma

In Beard v. Lincoln Nat’l Life Ins. Co., No. 25-2950, 2026 WL 1279959 (8th Cir. May 11, 2026), the Eighth Circuit affirmed judgment on the administrative record for Lincoln National Life Insurance Company on a claim for accidental death and dismemberment (AD&D) benefits under an ERISA-governed employer plan. Because the plan granted Lincoln National “discretionary authority to construe [its] terms … and to determine benefit eligibility,” the court reviewed for abuse of discretion and held that Lincoln National’s decision rested on a reasonable interpretation of the plan and was supported by substantial evidence.

Edward Beard had stage IV pancreatic cancer in December 2022 and, as side effects of his cancer and chemotherapy, experienced generalized weakness, chronic diarrhea, and an elevated clotting risk for which he took an anticoagulant. On December 16, 2022, Mr. Beard fell and hit his head while rushing to the bathroom. A CT scan in the emergency room was normal, and he was discharged. Early the next morning he became unresponsive, and a second CT scan revealed a large subdural hematoma compressing his brain. Mr. Beard died the following day. Tina Beard, his wife, submitted a claim for AD&D benefits under her husband’s ERISA-governed plan, which Lincoln National administered. After Lincoln National denied the claim and affirmed on appeal, Beard sued under 29 U.S.C. § 1132(a)(1)(B). The district court granted Lincoln National’s Rule 52(a)(1) motion on the administrative record, and Beard appealed.

Three plan provisions framed the appeal: the grant of “discretionary authority to construe [its] terms … and to determine benefit eligibility”; a coverage trigger paying AD&D benefits only when an employee suffered a loss “solely as the result of accidental Injury,” defined as “bodily impairment resulting directly from an accident and independently of all other causes”; and an exclusion barring coverage “for any loss that is contributed to or caused by … disease, bodily or mental illness (or medical or surgical treatment thereof).” Lincoln National’s final denial rested on both grounds, relying on reports from Dr. Robert Millstein and Dr. Keren McCarthy, who each concluded that Mr. Beard’s blood thinner usage contributed to the hematoma that caused his death.

The panel addressed two principal issues. First, on the standard of review, abuse-of-discretion review applied because the plan vested Lincoln National with discretionary authority. Reasonableness is measured by the five factors from King v. Hartford Life & Accident Ins. Co., 414 F.3d 994, 999 (8th Cir. 2005) (en banc).

Second, on the merits, the panel addressed coverage and the exclusion as independent grounds. On coverage, the court reaffirmed that an ERISA claimant bears the burden to show a claim falls within the scope of coverage. Beard had to show the fatal injury resulted directly from her husband’s fall “independently of all other causes,” and the panel held she had not. Drs. Millstein and McCarthy both concluded the anticoagulant contributed to the hematoma, Beard offered no contrary medical evidence during the administrative process, and her appellate briefing conceded that “the blood thinner probably did contribute to the hematoma,” that “an anticoagulant could have contributed to the size of the hematoma, which no one disputes,” and that “each doctor opined that the anti-coagulant made the hematoma bigger than it would have been … otherwise.”

On the disease/treatment exclusion, Lincoln National carried its independent burden to show the exclusion applied. Beard did not contest Lincoln National’s interpretation of “contribute” as “to give or furnish along with others towards bringing about a result,” leaving substantial evidence as the only remaining question. Dr. Millstein’s report explained that subdural hematomas “mainly occur” in anticoagulated patients, that anticoagulation roughly doubles the risk of death once a subdural hematoma develops, that fatal subdural hematomas are more strongly associated with anticoagulant use than nonfatal ones, and that a significant percentage of these deaths result from pressure on the brain as the hematoma expands. Dr. McCarthy reached the same conclusion. A reasonable mind could accept those opinions as adequate to support the conclusion that the anticoagulant “gave or furnished along with” the fall in bringing about Mr. Beard’s death.

The panel also rejected Beard’s argument that “contributed to” should be read to require but-for causation. That construction, the court explained, effectively conflated “contributed to” with “effective cause,” a term that “portrays a certain exclusiveness in that there cannot be two effective causes.” Because the plan grants discretion, the panel was required to defer to Lincoln National’s reasonable construction “even if [it] would interpret the language differently as an original matter.” Darvell v. Life Ins. Co. of N. Am., 597 F.3d 929, 935 (8th Cir. 2010). Beard conceded that Lincoln National’s interpretation was reasonable, and that concession bound the panel. The court also confirmed that judicial review is limited to the bases articulated in the final denial letter, Khoury v. Grp. Health Plan, Inc., 615 F.3d 946, 952 (8th Cir. 2010), and expressly declined to address whether Mr. Beard’s other infirmities, separate from the anticoagulant, would also have triggered the exclusion.