District Court’s Remand To Plan Administrator Is Not Final And Appealable

The Eleventh Circuit Court of Appeals recently ruled that a district court’s remand of a benefits claim to the plan administrator is not appealable to the circuit court.

The plaintiff in Young submitted a claim for long-term disability benefits, which was denied by Prudential. After she exhausted her administrative appeals, the plaintiff sued for benefits. On cross motions for summary judgment, the district court found in favor of the plaintiff and remanded the case to Prudential for reconsideration of whether the plaintiff was disabled. The district court clerk then entered what purported to be a final judgment and closed the case. Prudential initiated an appeal to the Eleventh Circuit, and while that appeal was pending, Prudential (in its capacity as plan administrator) determined that the plaintiff was disabled.

On appeal, the Eleventh Circuit held that it did not have jurisdiction because the district court’s remand was not a "final decision" under 28 U.S.C. § 1291. The remand did not end the case, the Eleventh Circuit noted, because it left unresolved whether the plaintiff was entitled to disability benefits. The district court therefore retains jurisdiction over the matter until a final decision on that issue is made.

This ruling on the limits of appellate jurisdiction over remand orders is in accord with similar decisions from the First, Eighth and Tenth Circuits.