Tina Beard v. Lincoln Nat'l Life Ins. Co.

── Tina Beard v. Lincoln Nat'l Life Ins. Co. ── Court: Court of Appeals for the Eighth Circuit Date: May 11, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-2950 ___________________________ Tina D. Beard Plaintiff - Appellant v. Lincoln National Life Insurance Company Defendant - Appellee ____________ Appeal from United States District Court for the Southern District of Iowa - Central ____________ Submitted: March 18, 2026 Filed: May 11, 2026 ____________ Before SHEPHERD, ERICKSON, and GRASZ, Circuit Judges. ____________ GRASZ, Circuit Judge. After Edward Beard passed away, his wife, Tina Beard, made a claim for accidental death and dismemberment (AD&D) benefits under his Employee Retirement Income Security Act (ERISA) plan, which was administered by Lincoln National Life Insurance Co. Lincoln Life denied her claim, explaining Mr. Beard’s death was not covered because it had not occurred “solely as the result of an accidental injury” and that a plan exclusion applied since the blood thinner Mr. Beard was using “contributed to” his death. Mrs. Beard then filed this lawsuit pursuant to ERISA, asking the district court 1 to reverse Lincoln Life’s denial. Lincoln Life moved for judgment on the administrative record, and the district court granted its motion, finding its interpretation of the plan was reasonable and that it supported its decision denying Mrs. Beard’s claim with substantial evidence. Mrs. Beard appeals, and we affirm. I. Background Mr. Beard was suffering from stage IV pancreatic cancer in December 2022. As side effects of his cancer and chemotherapy, he experienced generalized weakness and chronic diarrhea and faced an elevated risk of blood clots. Mr. Beard used a blood thinner to mitigate the risk of blood clotting. On December 16, 2022, Mr. Beard fell and hit his head while rushing to the bathroom. He went to the emergency room after he fell, and the doctors there conducted a CT scan. The results of the scan were normal, so the doctors discharged Mr. Beard, and he went home. Early the next morning, while Mr. and Mrs. Beard were sleeping, Mr. Beard became unresponsive and his breathing became irregular. Mrs. Beard called 911, and when paramedics arrived, they intubated Mr. Beard and took him back to the emergency room. Doctors conducted a second CT scan, and this time it showed Mr. Beard had developed a large subdural hematoma and that it had compressed his brain. Sadly, Mr. Beard died the following day. Mr. Beard was enrolled in his employer’s ERISA plan, which Lincoln Life administered, so Mrs. Beard submitted a claim for AD&D benefits. Her claim turns on three of the plan’s terms. First, the plan expressly affords Lincoln Life “discretionary authority to construe [its] terms . . . and to determine benefit eligibility . . . .” Second, the plan states that AD&D “benefits are payable when a Covered 1 The Honorable Rebecca Goodgame Ebinger, United States District Judge for the Southern District of Iowa. -2- Employee suffers a loss solely as the result of accidental Injury that occurs while covered,” and it defines “Injury” as “bodily impairment resulting directly from an accident and independently of all other causes.” And third, the plan excludes coverage “for any loss that is contributed to or caused by . . . disease, bodily or mental illness (or medical or surgical treatment thereof).” Lincoln Life denied Mrs. Beard’s claim, concluding in its final denial