ERISA-Third Circuit Dismissed Appeal From District Court’s Decision For Lack Of Jurisdiction

In Stevens v. Santander Holdings USA Inc. Self Insured Short Term Disability Plan, No. 14-1481 (3d Cir. 2015), plaintiff Joseph Stevens (“Stevens”), a former employee of a subsidiary of defendant Santander Holdings USA Inc. (“Santander”), brought suit against Santander seeking to recover benefits from two disability benefit plans that Santander provided for its eligible employees. As an employee of a Santander subsidiary, Sovereign Bank, Stevens participated in these plans, a short-term disability plan (“STD”) and a long-term disability plan (“LTD”). In October 2010, Stevens sought STD benefits through the administrator of Santander’s plans, defendant Liberty Life Assurance Company of Boston, doing business as Liberty Mutual (“Liberty Mutual”).

After it initially awarded STD benefits to Stevens, Liberty Mutual determined that Stevens no longer suffered from a qualifying disability, a determination that led it to terminate his STD benefits. Stevens then brought this suit under ERISA, seeking reinstatement of the payment of benefits. The district court found that Liberty Mutual’s decision to terminate Stevens’s STD benefits was arbitrary and capricious and remanded the case to the plan administrator with instructions to reinstate Stevens’s STD benefit payments retroactively, and to determine his eligibility for LTD benefit payments.

Santander and Liberty Mutual appealed the district court’s decision to the Third Circuit Court of Appeals (the “Court”). However, Stevens moved to dismiss the appeal for lack of jurisdiction, arguing that the district court’s remand order to the plan administrator was not a “final decision” appealable pursuant to 28 U.S.C. § 1291 at that time. Upon review, the Court held that the district court has retained jurisdiction over the case, and that the order from which the defendants have appealed is not yet appealable. Therefore, the Court dismissed the appeal for lack of jurisdiction.

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