Dickens v. Aetna Life Insurance
677 F.3d 228
4th Cir.2012Background
- Dickens, an employee of BMS, participated in the BMS LTD plan and was initially awarded LTD benefits.
- SSA later awarded Dickens disability benefits; Aetna terminated Dickens's LTD benefits in 2008 based on its assessment.
- Dickens filed suit under ERISA to restore LTD benefits; SSA continued benefits despite Aetna’s termination.
- District court denied summary judgment and remanded for reconsideration by Aetna; the court did not resolve the merits.
- Aetna appealed the remand order; the Fourth Circuit raised jurisdiction sua sponte and dismissed the appeal for lack of appellate jurisdiction.
- The district court had remanded to Aetna to reweigh evidence, including SSA’s disability determination; the remand did not constitute a final, appealable order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the remand order appealable as a collateral order? | Dickens contends the order resolves a dispositive, separable issue and thus is appealable. | Aetna argues the order is a collateral-order appealable under the collateral order doctrine. | No; collateral-order jurisdiction does not attach. |
| Does the order satisfy collateral-order requirements (conclusive, separable, unreviewable)? | Order conclusively determines the evidentiary standard for benefits. | Order is interwoven with merits and not conclusively separable or unreviewable. | It does not satisfy all three requirements. |
| Does remand to ERISA administrator for reconsideration count as a final, appealable decision under §1291? | Remand can be treated as final because it disposes of key issues and ends the case on remand. | Remand to an administrative body is not a final decision; no final judgment exists. | Remand here is not a final decision under §1291. |
Key Cases Cited
- Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (1977) (sua sponte jurisdiction considerations for appellate review)
- Catlin v. United States, 324 U.S. 229 (1945) (final decision concept for §1291)
- Will v. Hallock, 546 U.S. 345 (2006) (collateral-order doctrine criteria)
- Mohawk Indus., Inc. v. Carpenter, 130 S. Ct. 599 (2009) (collateral-order doctrine limitations)
- Borntrager v. Cent. States, Se. & Sw. Areas Pension Fund, 425 F.3d 1087 (2005) (ERISA remand performance and finality considerations)
- Bowers v. Sheet Metal Workers' Nat'l Pension Fund, 365 F.3d 535 (2004) (remand to ERISA administrator and finality)
- Young v. Prudential Ins. Co. of Am., 671 F.3d 1213 (2012) (remand to ERISA claimant for reconsideration not appealable)
- Hensley v. Nw. Permanente P.C. Ret. Plan & Trust, 258 F.3d 986 (2001) (collateral-order analysis for remand orders)
- Perlman v. Swiss Bank Corp. Comprehensive Disability Prot. Plan, 195 F.3d 975 (1999) (sentence-four remand and finality concepts)