Card v. Principal Life Ins. Co.

Card v. Principal Life Ins. Co.

Opinion

 [*622]  [***1]   The court delivered a PER CURIAM opinion. MURPHY, J. (pp. 9-13), delivered a separate concurring opinion.

 [***2]  PER CURIAM. This case under the Employee Retirement Income Security Act (ERISA) reaches our court for a second time. On Susan Card's first appeal, we found that the administrator of her disability plan arbitrarily denied her benefits, so we ordered a remand to the plan administrator for it to take a second look at her claims. See Card v. Principal Life Ins. Co., 790 F. App'x 730, 732 (6th Cir. 2019). When Card filed various motions in the district court after this remand, the district court held that it lacked jurisdiction because we had bypassed [**2]  the court and remanded Card's case directly to the administrator. Card now appeals this jurisdictional ruling. The ruling requires us to address how "remands" to plan administrators should work. Because a district court retains jurisdiction over a beneficiary's ERISA suit during the remand, we vacate the court's order holding that it lacked jurisdiction and remand for it to consider Card's motions.

In February 2013, a doctor diagnosed Card with "chronic lymphocytic leukemia," a slow-growing blood cancer that can cause fatigue. See id. at 732 & n.1. By the following December, Card alleges, her worsening fatigue left her unable to perform her job as a night-shift nurse at a long-term care and skilled rehabilitation center. Id. at 732-33. She applied for disability benefits under an ERISA-governed plan administered by Principal Life Insurance Company. Id. at 733. Principal Life denied her requests for short-term, long-term, and total disability benefits on the ground that she did not fall within the plan's various "disability" definitions. Id. at 733-34.

Card sued Principal Life seeking these benefits under ERISA. The district court granted summary judgment to Principal Life. Id. at 734. We reversed. [**3]  The plan delegated discretionary claims-processing authority to Principal Life, so we reviewed its denial of benefits under the deferential arbitrary-and-capricious test. See id. at 734-36. But we held that Principal Life's denial failed this test. Id. at 737-43. The plan's definition of short-term disability turned on  [***3]  whether beneficiaries could perform the essential tasks of their specific jobs; its definition of long-term disability turned on whether beneficiaries could perform the essential tasks of their general occupations. Id. at 737-39. We reasoned that Principal Life had not analyzed whether Card's cancer prevented her from performing the tasks of her job or occupation. Id. at 738-42.

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