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 Attorneys
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.
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Partner David Greenwald to Speak at PLI Program on Privilege and AI
On August 17, David Greenwald will speak at "Fitting New “Tech” Into the Attorney-Client Privilege and Work Product Protection," a virtual program hosted by the Practising Law Institute (PLI).
August 17, 2026
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In Law360, Trump Debarment Threat Calls for Targeted Defense Plan
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August 6, 2026
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"DC Circuit Undercuts Congress's Subpoena Power: Important New Authority for Targets of Congressional Investigations," National Law Journal
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July 30, 2026
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Meghan Greenfield Discusses Top Environmental Policies to Watch in Law360
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July 22, 2026
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Partner Meghan Greenfield Quoted in The Associated Press on Offshore Wind and National Security
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July 21, 2026