District Court Upholds Denial of Accidental Death Benefits Where Dialysis Treatment Contributed to Death

In Kleinsteuber v. Metropolitan Life Insurance Company, No. CV 23-3494 (JRT/DTS), 2025 WL 2403123 (D. Minn. Aug. 19, 2025), the United States District Court for the District of Minnesota considered whether MetLife abused its discretion in denying accidental death and dismemberment (AD&D) benefits following the tragic death of a dialysis patient. The decision highlights how courts analyze ERISA policy exclusions for deaths “caused or contributed to” by illness or medical treatment, and it underscores the deferential standard of review applied to discretionary plan determinations.

Charles Kleinsteuber’s wife, Dana, suffered from end-stage renal disease and self-administered dialysis at home. In January 2022, while completing a treatment, her port line dislodged, causing catastrophic blood loss. First responders were unable to save her, and the medical examiner listed her cause of death as natural, attributable to ESRD.

MetLife, the administrator of Charles’s group life and AD&D insurance, promptly paid out life insurance benefits but denied the AD&D claim. Citing the policy’s exclusion for losses “caused or contributed to by” illness or treatment, MetLife determined Dana’s death was excluded because dialysis treatment for ESRD was involved. Charles appealed, submitting medical evidence—including a letter from Dana’s treating physician asserting her death was accidental and not caused by ESRD or its treatment. MetLife again denied the claim, and Charles brought suit under ERISA § 502(a)(1)(B).

Because the policy granted MetLife discretionary authority, the court applied the abuse of discretion standard. Under this deferential review, MetLife’s decision would be upheld so long as its interpretation of the policy was reasonable and supported by substantial evidence.

The court applied factors set forth in Finley v. Special Agents Mut. Benefit Ass’n, 957 F.2d 617, 621 (8th Cir. 1992) (the Finley factors), which guide the Eighth Circuit’s analysis of whether an administrator’s interpretation of plan terms is reasonable. Several factors weighed in MetLife’s favor:

Consistency with plan goals: While AD&D coverage is meant to provide additional protection for accidental deaths, exclusions for risks associated with medical treatment serve the legitimate purpose of controlling costs and limiting exposure.

Plan language: The exclusion’s wording—covering deaths “caused or contributed to by treatment of illness”—was broad. The court found MetLife’s reading consistent with that language.

ERISA procedural compliance: Although the initial denial letter was imperfect in describing what additional information was needed to perfect the claim, the overall process gave Charles a fair chance to appeal, and MetLife considered all evidence, including the treating physician’s opinion.

Consistency of interpretation: Courts around the country have upheld MetLife’s consistent reliance on this exclusion in similar cases where deaths occurred during medical treatment. See, e.g., Wheeler v. Metro. Life Ins. Co., No. 1:11-603, 2012 WL 13005523, at *2, 4 (E.D. Tex. Sept. 10, 2012) (“[T]his accidental death was specifically caused by the treatment for an existing illness—elective surgery for her bladder incontinence.”); Rustad-Link v. Metro. Life Ins. Co., No. 13-111, 2014 WL 3956761, at *2–3 (D. Mont. Aug. 13, 2014) (MetLife taking the position that an exclusion applied when a mistakenly placed intravenous line to administer medication resulted in sepsis and eventual amputation).

Conflict of interest: While MetLife both administered and paid claims, the court gave this factor only “minor to moderate” weight, finding no evidence of bias or procedural irregularities.

Overall, the court concluded that MetLife’s interpretation of the exclusion was reasonable.

The second step was whether substantial evidence supported the application of that interpretation. The record established that Dana was undergoing dialysis, failed to close her port correctly, and bled to death. The court found this created a direct connection between the treatment and her death. Unlike cases where illness merely triggered an accident (e.g., a seizure causing a car crash), here the dialysis procedure itself “directly contributed” to the fatal blood loss.

Because the evidence showed that the treatment was an integral cause of death, the exclusion applied.

The court denied Charles’s motion for summary judgment and granted MetLife’s, finding no abuse of discretion in MetLife’s denial of AD&D benefits.