Background
Mrs. Kleinsteuber died after dislodging a chest port while using home dialysis for end-stage renal disease. Her husband filed a claim for accidental death and dismemberment benefits under an ERISA plan administered by MetLife. MetLife denied the claim, stating the death was caused or contributed to by her physical illness and treatment. The district court granted summary judgment in favor of MetLife.
The court’s reasoning
The court found MetLife conducted a full and fair review of the claim. Although the plan granted MetLife discretion, the administrator did not exercise it to interpret the exclusion terms, requiring de novo review. Under common meaning, the exclusion applied because the dialysis treatment was one of the reasons for the death. The court also found substantial evidence supported the denial, as the claimant’s failure to close the port led to the blood loss that caused her death.
Had Mrs. Kleinsteuber not been receiving dialysis to treat her ESRD she would not have had a port line. Additionally, she would not have been interacting with a dialysis machine. Without the dialysis machine and port line the death of Mrs. Kleinsteuber as it occurred would not have been possible.
Opinion at page 4
What it means going forward
The decision reinforces that ERISA administrators must provide clear notice of denials but are not required to address every piece of evidence submitted if the final decision is supported by substantial evidence.
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