In Employee Relations Law Journal: What Happens When ERISA Disability Deadlines Slip
Partner Joseph Torres along with Associates Emma O'Connor and Christopher LeWarne, authored an article for the Employee Relations Law Journal analyzing a significant Fourth Circuit decision with substantial consequences for ERISA disability plan administrators.
The article examines Cogdell v. Reliance Standard Life Insurance Co., in which the Fourth Circuit affirmed that a plan administrator's failure to meet its 45-day appeal deadline, without valid special circumstances, triggers de novo review in federal court, stripping the administrator of the deferential standard it would otherwise enjoy.
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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
Partner Joseph Torres along with Associates Emma O'Connor and Christopher LeWarne, authored an article for the Employee Relations Law Journal analyzing a significant Fourth Circuit decision with substantial consequences for ERISA disability plan administrators.
The article examines Cogdell v. Reliance Standard Life Insurance Co., in which the Fourth Circuit affirmed that a plan administrator's failure to meet its 45-day appeal deadline, without valid special circumstances, triggers de novo review in federal court, stripping the administrator of the deferential standard it would otherwise enjoy.
Related Lawyers
Related Capabilities
© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
News and Insights
Event
Partner Terri Mascherin to Speak at Illinois State Bar Association Seminar on Negotiation Ethics
On November 11, Partner Terri Mascherin will join a faculty panel for the Illinois State Bar Association (ISBA) continuing legal education (CLE) seminar “Negotiation Ethics: Winning Without Selling Your Soul.”
November 11, 2026
Publications
Before You Sign: Key Contract Provisions for Tribes Considering Data Center Developments, ICT
Grace Signorelli-Cassady of Jenner & Block’s Native American Law Practice authored an opinion piece for ICT examining key contract provisions tribes should consider when approached about data center developments.
November 5, 2026
Publications
Jon Skladany and Kayvan Sadeghi Quoted on Fintech Investigation Readiness in Law360
Jenner & Block Partners Jon Skladany and Kayvan Sadeghi were quoted in a Law360 article examining how crypto and fintech companies are preparing for heightened congressional oversight following the 2026 midterm elections.
November 5, 2026
Publications
Partner Emily Loeb Discusses What the 2026 Midterms Mean for Congressional Oversight in the Financial Times
Partner Emily Loeb, co-chair of Jenner & Block’s Congressional Investigations Practice, was quoted in the Financial Times in an article examining how companies are preparing for congressional oversight as the new Congress takes shape following the 2026 midterm elections.
November 4, 2026
Recognition
Three Jenner & Block Partners Named 2026 Law360 MVPs
Law360 named Jenner & Block Partners Adam Unikowsky, Lindsay Harrison, and Rebekah Goodheart to its 2026 MVPs list.
November 3, 2026
Publications
Congressional Oversight after Trump v. United States, Lawfare
Special Counsel David Manners-Weber authored an article for Lawfare examining how the Supreme Court’s 2024 decision in Trump v. United States may weaken Congress’s ability to investigate the executive branch.
November 2, 2026
Publications
In Politico, Partner Emily Loeb Discusses How Companies Are Preparing for Congressional Oversight
Partner Emily Loeb was spoke with Politico for a story examining how companies are preparing for heightened congressional oversight, particularly those that could become the focus of investigations centered on affordability and accountability.
October 29, 2026