e-Journal Summary

e-Journal Number : 76426
Opinion Date : 11/02/2021
e-Journal Date : 11/15/2021
Court : U.S. Court of Appeals Sixth Circuit
Case Name : Card v. Principal Life Ins. Co.
Practice Area(s) : Employment & Labor Law Litigation
Judge(s) : Per Curiam – McKeague and Nalbandian; Concurrence – Murphy
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Employee Retirement Income Security Act (ERISA); Disability benefits under an ERISA-governed plan; Appellate jurisdiction; Whether the district court order was a “final decision” for purposes of appeal; Whether the district court retained jurisdiction over the case when it was remanded to the plan administrator


The court held that a district court retains jurisdiction over an ERISA case when an appellate court remands the case to a plan administrator; thus, the district court here erred by ruling that it lacked jurisdiction to consider plaintiff-beneficiary’s (Card) motions filed after that remand. Card was denied disability benefits under an ERISA-governed plan administered by defendant-Principal Life Insurance Company. The court previously held that the denial was arbitrary and remanded the case to the administrator. After remand, Card filed motions to reopen and for attorney’s fees with the district court, but it held that it lacked jurisdiction because the court had remanded the case directly to the administrator. The court first held that the district court’s jurisdictional ruling was a “final decision” that was appealable. It then held that the district court had jurisdiction to consider Card’s motions. Under Sixth Circuit precedent, when an administrator’s decision is “arbitrary and capricious for a procedural reason . . . . a court should ‘remand’ the beneficiary’s claims to the plan administrator for a second benefits determination.” The court concluded that “[a]s in every other ERISA case in this procedural posture, we interpret our prior decision as remanding to the district for it to retain jurisdiction while Principal Life engaged in the new benefits determination.” Thus, it vacated the district court’s order and remanded for consideration of Card’s motions.

Full PDF Opinion