I get 3D from Netflix on my PS3 and my Sony S5100. It's working here. But it is sometimes inconsistent. If I can get SuperHD I can get the 3D streams. I check with the example short first. If SuperHD shows up I know I'm fine to stream the 3D. If the SuperHD doesn't show up I back out of Netflix and start it again. Usually it's fine on the first try. But sometimes. it can take a few tries until the SuperHD and 3D streams show up.
Plus even if you can get the 3D streams, Netflix says you need a 12Mbps connection to stream without issues.