Contrasting Outcomes in AD&D Litigation: What Made the Difference?

A recent case in Minnesota demonstrates the complexities of an accidental death related to an underlying medical condition. In Kleinsteuber v. Metropolitan Life Insurance Company[1], a woman died due to acute blood loss after she accidentally failed to close a port and subsequently dislodged a line while self-administering kidney dialysis at home. Despite the circumstances, the county Medical Examiner determined the cause of death as natural, with her death certificate listing end-stage renal disease (ESRD) and natural causes.

A claim was submitted for both life insurance claim and accidental death and dismemberment (AD&D) benefits to MetLife, the insurance carrier. MetLife approved the life insurance claim but initially denied the AD&D claim, citing the death certificate’s indication of natural causes. Upon review, MetLife denied the AD&D claim again, stating that the death was not accidental and, even if it were, that a policy exclusion applied because the death was caused or contributed to by the treatment of her ESRD.

The district court found that MetLife’s interpretation of the policy exclusion was reasonable, ultimately determining that the dialysis treatment “contributed to” the death because the treatment exposed the deceased to the circumstances that led to her death.

That rationale differs from others where benefits were paid under similar circumstances. One comparison is to Genal v. Prudential Ins. Co. of America[2]. In that case, the decedent had suffered from multiple sclerosis for approximately twenty-five years, which had progressed such that he required the use of a wheelchair. Shortly before his death, the decedent’s wheelchair had broken and he was using a motorized scooter. At the time of his death, he was found unresponsive in his backyard, with the scooter nearby in the grass near some flat stones beside a concrete patio. According to police investigators and the Medical Examiner, it appeared that he had fallen from the scooter either while dismounting or while pushing the scooter, and he was unable to rescue himself once he fell.

The court rejected the Prudential’s argument that Genal’s multiple sclerosis contributed to his death and ruled that his death qualified as an accident under his AD&D policy. “The evidence indicates that the cause of the Decedent’s death was initially triggered by the fall from the scooter and not his illness. While the fall by itself may not have caused Decedent’s death, but for the fall, Decedent would not have died.”

The comparison of these two cases illustrates the complexity of ERISA AD&D claims. Entitlement to benefits can hinge on small differences in policy wording, the applicable standard of review, or the case law in a particular jurisdiction.

[1] Kleinsteuber v. Metro. Life Ins. Co., No. CV 23-3494 (JRT/DTS), 2025 WL 2403123, at *1 (D. Minn. Aug. 19, 2025)

[2] Genal v. Prudential Ins. Co. of Am., No. CA 6:11-182-TMC, 2012 WL 2871777, at *1 (D.S.C. July 12, 2012)

 

source https://www.reynoldsand.com/contrasting-outcomes-in-add-litigation/