The U.S. Court of Appeals for the Eleventh Circuit affirmed a district court decision upholding Metropolitan Life Insurance Company's denial of accidental death benefits in *Brittany Finney v. Metropolitan Life Insurance Company* (11th Cir. 2026). The published opinion, filed Jan. 26, 2026, addresses the complex intersection of accidental injury and pre-existing health conditions in insurance coverage disputes.
The case centers on Selina Anderson, who died less than a week after suffering an accidental leg fracture. Anderson fell while exiting a vehicle in an athletic field parking lot, sustaining what medical records described as a markedly swollen and deformed knee. X-rays revealed her leg was broken in two places, requiring immediate orthopedic surgery.
Despite the surgery's initial success, Anderson's body could not withstand the surgical stress due to her underlying chronic diseases. Complications developed rapidly, including a blood clot that lodged in her lung and caused severe damage to lung tissue. She subsequently developed pneumonia, diffuse alveolar damage, and bilateral subpleural fibrosis before dying within a week of the accident.
Anderson's daughter, Brittany Finney, filed a claim for accidental death benefits under her mother's insurance policy. Metropolitan Life denied the claim, invoking a policy exclusion that bars payment when the insured's physical or mental illness contributed to the death. The insurance company argued that Anderson's chronic diseases materially contributed to her death, even though the initial injury was clearly accidental.
Finney challenged the denial in the U.S. District Court for the Northern District of Alabama, arguing that her mother's death resulted from the accidental injury, not pre-existing conditions. The district court ruled in favor of Metropolitan Life, finding that the insurance company's decision was not arbitrary or capricious under the applicable standard of review.
On appeal, the Eleventh Circuit panel consisting of Circuit Judges Rosenbaum, Grant, and Brasher examined whether the district court properly applied the arbitrary and capricious standard to Metropolitan Life's benefits determination. In insurance cases governed by ERISA, courts must determine whether a plan administrator's decision was reasonable based on the evidence available at the time.
Circuit Judge Grant, writing for the court, emphasized the tragic nature of Anderson's unexpected death while acknowledging the legal complexities involved. The opinion noted that Anderson "did not expect her life to end shortly after she broke her leg," but years of chronic disease had left her particularly vulnerable to surgical complications.
The court's analysis focused on the policy's specific language regarding illness exclusions and how they apply when both accidental injury and pre-existing conditions contribute to a death. The insurance policy excluded coverage when physical or mental illness "contributed to" the death, creating a question of causation that required careful examination of the medical evidence.
Metropolitan Life's position centered on medical evidence showing that Anderson's chronic diseases significantly compromised her ability to survive the surgical intervention necessitated by her accident. The company argued that while the leg fracture was undeniably accidental, the ultimate cause of death was her body's inability to handle surgical stress due to pre-existing health conditions.
The court found that Metropolitan Life's interpretation of the policy exclusion was reasonable and supported by medical evidence. The decision reflects the challenging reality that accident victims with serious underlying health conditions may face insurance coverage gaps when their pre-existing conditions contribute to post-accident complications.
This case illustrates broader issues in accidental death insurance, particularly regarding causation analysis when multiple factors contribute to a death. Insurance companies frequently invoke illness exclusions in cases where accidental injuries trigger fatal complications in individuals with compromised health.
The Eleventh Circuit's affirmance establishes precedent for how courts should evaluate insurance denials involving the interplay between accidental injuries and pre-existing conditions. The decision may influence similar cases throughout Alabama, Florida, and Georgia, which fall within the Eleventh Circuit's jurisdiction.
For insurance policyholders, the ruling underscores the importance of understanding policy exclusions and their potential application in complex medical scenarios. Individuals with chronic health conditions may need to consider supplemental coverage or different policy terms to ensure adequate protection.
The case also highlights the challenges facing beneficiaries who must navigate insurance company decisions during grief and financial stress. While courts apply deferential review standards to insurance company determinations, beneficiaries retain the right to challenge denials they believe are improper.
Legal practitioners representing insurance beneficiaries should note the court's emphasis on medical evidence and policy language interpretation. Success in challenging insurance denials often depends on demonstrating that the insurance company's decision lacked reasonable support in the administrative record.
The published nature of this opinion ensures it will serve as binding precedent within the Eleventh Circuit and persuasive authority in other jurisdictions facing similar insurance coverage disputes involving accidental death benefits and pre-existing health conditions.