Cheryl G. Young v. The Prudential Insurance Company of America
671 F.3d 1213
11th Cir.2012Background
- Young, a Florida Coastal School of Law professor, had long-term disability coverage under Prudential’s Plan.
- She has multiple sclerosis and claims disability prevent work; Prudential denied benefits then denied on administrative appeal.
- District court granted partial summary judgment for Young and remanded to Prudential to determine disability in the first instance.
- Clerk entered what purported to be a final judgment against Prudential; Prudential appealed on §1291 grounds.
- Prudential later acted on remand as plan administrator and determined Young was disabled.
- This court sua sponte reviews jurisdiction and concludes the district court’s order is not final or appealable under the collateral order doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the remand/partial summary judgment a final §1291 decision? | Young contends remand did not end merits. | Prudential argues finality because district court ordered judgment. | No; not a final decision under §1291. |
| Does collateral order doctrine apply to the remand order? | Young argues collateral review is appropriate. | Prudential contends collateral order exception applies. | No; order concerns merits and is not collateral. |
| Can Prudential seek review after final decision following plan administrator’s remand? | N/A (argues jurisdiction should exist for immediate review). | Authority allows review after final decision following remand. | Yes; jurisdiction retained to review after final decision. |
Key Cases Cited
- Shannon v. Jack Eckerd Corp., 55 F.3d 561 (11th Cir. 1995) (remand orders are not final judgments)
- Petralia v. AT&T Global Info. Solutions Co., 114 F.3d 352 (1st Cir. 1997) (interpret remand to preserve jurisdiction for review)
- Bowers v. Sheet Metal Workers’ Nat’l Pension Fund, 365 F.3d 535 (6th Cir. 2004) (adopts view that remand preserves jurisdiction)
- Graham v. Hartford Life & Accident Ins. Co., 501 F.3d 1153 (10th Cir. 2007) (finality/appealability of remands under ERISA)
- Borntrager v. Cent. States, Se. & Sw. Areas Pension Fund, 425 F.3d 1087 (8th Cir. 2005) (remand orders and finality considerations)
- Thomas v. Blue Cross & Blue Shield Ass’n, 594 F.3d 823 (11th Cir. 2010) (substance of order governs finality, not label)