Background
Tina Beard sought accidental death and dismemberment benefits under her late husband Edward Beard’s ERISA plan administered by Lincoln National Life Insurance Company. Edward Beard, suffering from stage four pancreatic cancer and taking blood thinners, fell and hit his head. He later died from a subdural hematoma. Lincoln Life denied the claim, stating the death was not solely the result of an accident and that the blood thinner contributed to the fatal injury.
The court’s reasoning
The Eighth Circuit applied an abuse of discretion standard because the plan granted the administrator discretionary authority. The court found Mrs. Beard failed to meet her burden of showing the injury resulted independently of all other causes, as she conceded the blood thinner contributed to the hematoma. The court also found substantial evidence supported the insurer’s application of the disease exclusion, relying on medical experts who concluded the blood thinner contributed to the death.
Mrs. Beard did not show Mr. Beard’s hematoma was caused by his fall, independently of all other causes, her claim was not covered.
Beard v. Lincoln Nat’l Life Ins. Co., No. 25-2950 (8th Cir. May 11, 2026)
What it means going forward
The ruling reinforces that ERISA claimants must prove their injury was independent of other causes to trigger coverage and that insurers may rely on medical evidence showing a contributing factor to deny claims under disease exclusions.
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