Our blogpost of September 16, 2014 featured the decision in Mead v. Reliastar Life Ins. Co., 768 F.3d 102 (2d Cir. 2014), wherein the Second Circuit held that a remand order is generally not appealable (for lack of finality). On August 24, 2015, the Third Circuit reached the same conclusion for substantially the same reasons.
Stevens v. Santander Holdings USA Inc., 799 F.3d 290 (3d Cir. 2015)
In our blogpost of August 13, 2014, we featured the decision in Moyer v. Metropolitan Life Ins. Co., 762 F.3d 503 (6th Cir. 2014), wherein it was held that an insurer cannot invoke a statute of limitations defense that is grounded on plan language unless mention of the language was made in the insurer’s denial letter. One year later, the Third Circuit expressed the exact same view.
Plan-based time limitations are commonplace, and they often serve to drastically shorten the period during which suit may be brought. Accordingly, the Third Circuit’s decision, in tandem with that of the Sixth Circuit, is a significant victory for ERISA disability claimants.
Mirza v. Insurance Adm’r of Am., Inc., 800 F.3d 129 (3d Cir. 2015)