Northern District of Texas Holds Plaintiff Failed to Prove Eye Injury Was Sole Cause of Vision Loss, Upholds Denial of Accidental Dismemberment Benefits

In Langley v. Metropolitan Life Insurance Co., No. 3:24-CV-2832-K, 2026 WL 865736 (N.D. Tex. Mar. 30, 2026), a Southwest Airlines aircraft inspector sought accidental dismemberment benefits after losing vision in his left eye following an incident in which he lifted heavy wing panels during an inspection. He was subsequently diagnosed with Central Retinal Vein Occlusion (CRVO) with macular edema and retinal hemorrhaging. MetLife denied the claim on the ground that the accidental injury was not the direct and sole cause of the vision loss, and the district court agreed.

The Rule 52 Procedural Dispute

Before reaching the merits, the court addressed a procedural skirmish that practitioners in the ERISA space will find familiar. MetLife moved for judgment on the administrative record under Federal Rule of Civil Procedure 52, which governs findings of fact and conclusions of law. The plaintiff argued that such a motion is not authorized by the Federal Rules and urged the court to treat it instead as a motion for summary judgment — a recharacterization that would have required the plaintiff only to demonstrate a genuine dispute of material fact rather than to satisfy the preponderance-of-the-evidence burden that applies at trial.

The court rejected the argument. Judge Kinkeade cited a well-developed line of authority within the Fifth Circuit holding that Rule 52 is the proper vehicle for resolving ERISA benefit disputes on the administrative record, including the Fifth Circuit’s own recent decision in Wicks v. Metropolitan Life Insurance Co., No. 23-11247, 2024 WL 4212891 (5th Cir. Sept. 17, 2024), which affirmed a district court’s use of de novo review under Rule 52. Other district courts in the circuit — including prior decisions by Judge Kinkeade himself — have consistently employed this framework. See Bellace v. Hartford Life & Accident Insurance Co., No. 3:24-CV-00136-K, 2025 WL 2345157 (N.D. Tex. Aug. 13, 2025).

Merits: Sole Causation and the Administrative Record

Applying de novo review under Rule 52, Judge Kinkeade independently weighed the administrative record and found the plaintiff had not carried his burden by a preponderance of the evidence. The court’s analysis turned heavily on the treating physicians’ own admissions. The retinal specialist answered “No” on MetLife’s claim form when asked whether the injury was solely responsible for the loss and further indicated that the plaintiff’s vision had not been irrevocably reduced to the 20/200 threshold required by the Plan’s definition of loss of sight. The optometrist acknowledged that heavy lifting could contribute to CRVO but stated she could not determine what actually caused the CRVO, or whether it would have occurred regardless of the physical demands of the plaintiff’s job.

The court also noted the plaintiff’s pre-existing history of multiple bilateral eye conditions and hypertension — a recognized risk factor for CRVO — as additional grounds undermining sole causation. The Plan required that any covered loss occur “independent of other causes,” and the record simply could not support that showing.

The court sustained MetLife’s objections to materials in the plaintiff’s response appendix that were not part of the administrative record, though it noted the outcome would have been the same even if those materials had been considered.