Second Circuit: Mead v. Reliastar Life Insurance Company

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U.S. Court of Appeals for the Second Circuit – ERISA – Appellate Jurisdiction

Mead v. Reliastar Life Insurance Company

11-192

Judges Winter and Hall

Background: The plaintiff suffers from degenerative cervical disc disease and sought long-term disability benefits, asserting that her disability prevented her from performing her occupation or any other. The insurance company denied her claim and she commenced an action under the Employee Retirement Income Security Act. The insurance company appealed the district court’s order directing the defendant to calculate the amount of benefits owed because she was unable to perform the duties of her own occupation and determine whether she was eligible for additional benefits.

Ruling: The Second Circuit dismissed the appeal. The court held that it did not have appellate jurisdiction as the district court did not enter a final judgment but instead remanded her claim for ERISA benefits to the insurance plan administrator for further consideration.

Jonathan M. Feigenbaum for the plaintiff-appellee; William D. Hittler of Nilan Johnson Lewis for the defendant-appellant