Eighth Circuit Upholds AD&D Denial, Holding Home Dialysis Treatment Contributed to Insured’s Death Within the Plan’s Illness-Treatment Exclusion

In Kleinsteuber v. Metropolitan Life Insurance Company, — F.4th —-, 2026 WL 1502873 (8th Cir. May 29, 2026), the Eighth Circuit affirmed summary judgment for Metropolitan Life Insurance Company (“MetLife”), upholding its denial of accidental death and dismemberment (“AD&D”) benefits to Plaintiff following the death of his wife. The decedent had developed end-stage renal disease (“ESRD”) and used home dialysis to treat the condition. She died of cardiac arrest brought on by severe blood loss after she failed to close the chest port used to administer her dialysis. MetLife initially declined the claim on the ground that the death resulted from natural causes rather than an accident, but after Plaintiff submitted an administrative appeal exceeding 1,000 pages, including a letter from the decedent’s physician, MetLife conceded the death was accidental. It nonetheless maintained that the plan’s exclusion for any loss “caused or contributed to by … physical or mental illness or infirmity, or the diagnosis or treatment of such illness or infirmity” applied because the decedent’s home dialysis treatment contributed to her death.

Plaintiff raised four issues on appeal: whether MetLife conducted a full and fair review, whether the district court gave MetLife’s conflict of interest sufficient weight, whether MetLife’s interpretation of the exclusion was reasonable, and whether substantial evidence supported the denial. The court addressed the first two issues first because they bore on the applicable standard of review. On full and fair review, the court rejected Plaintiff’s contention that MetLife’s initial denial letter failed to state the specific reasons for the determination, explaining that ERISA’s notice requirements are assessed by reference to all of the administrator’s communications rather than the initial letter alone, and that MetLife’s letters adequately conveyed that the claim was denied under the exclusion because the decedent’s home dialysis caused or contributed to her death. The court agreed that neither denial letter described additional material needed to perfect the claim, but held that no such description was required because MetLife denied the claim on the application of the exclusion’s language to undisputed facts rather than on missing information.

On the conflict of interest, the court acknowledged MetLife’s inherent conflict as both administrator and payer but agreed with the district court that the conflict warranted little weight, noting that Plaintiff identified no evidence connecting the perceived deficiencies in MetLife’s investigation to its decision. The court added that review is confined to the final claims decision, that MetLife was obligated to reconsider its accidental-death conclusion upon receiving the physician’s letter rather than faulted for doing so, and that ERISA’s regulations require an administrator only to take submitted information into account, not to discuss specific evidence.

Turning to interpretation of the exclusion, the court observed that although the plan granted MetLife discretionary authority to construe its terms, MetLife had not actually explained how it interpreted “caused” or “contributed to” in its final denial letter. Because MetLife did not exercise its discretion to interpret those terms, the court reviewed their meaning de novo, giving the language its common and ordinary meaning. Drawing on dictionary definitions, the court determined that “cause” means something that brings about a result and “contribute” means to be one of the reasons something happens, such that the exclusion applied if the decedent’s ESRD or home dialysis brought about or was one of the reasons for her death.

On substantial evidence, the court reviewed MetLife’s application of the exclusion to the facts for abuse of discretion. It concluded that the physician’s letter and the sheriff’s and medical examiner’s reports, which recounted that the decedent died from critical blood loss after failing to close her port, constituted evidence a reasonable mind could accept as adequate to support MetLife’s determination that home dialysis contributed to her death. The court rejected Plaintiff’s arguments that closing a chest port is not part of dialysis, that the dialysis contributed only to the accident rather than the death, and that MetLife improperly weighed the evidence, reasoning that closing the port is the final step of the treatment, that the failure to close the port necessarily led to the fatal blood loss, and that the court cannot substitute its own weighing of the evidence for the administrator’s. The court affirmed the district court’s judgment and upheld MetLife’s denial of the claim.