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Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242, 130 S.Ct. 2149, 176 L.Ed.2d 998, 78 USLW 4448, 49 Employee Benefits Cas. 1001, 10 Cal. Daily Op. Serv. 6279, 2010 Daily Journal D.A.R. 7481, Pens. Plan Guide (CCH) P 24007B, 22 Fla. L. Weekly Fed. S 351

Facts

Bridget Hardt filed for long-term disability benefits after medical issues forced her to stop working. After exhausting her administrative remedies, she sued Reliance, her employer's disability insurance carrier, alleging wrongful denial of her benefits claim under ERISA. The District Court found that Reliance's denial was based on incomplete medical information and remanded the case for further consideration. Following the remand, Reliance awarded Hardt the benefits she sought, and she subsequently moved for attorney fees under ERISA's fee-shifting statute.

Bridget Hardt filed for long-term disability benefits after medical issues forced her to stop working.

Issue

Did the Court of Appeals correctly conclude that § 1132(g)(1) permits courts to award attorney's fees only to a 'prevailing party'?

Did the Court of Appeals correctly conclude that § 1132(g)(1) permits courts to award attorney's fees only to a 'prevailing party'?

Rule

A fee claimant need not be a 'prevailing party' to be eligible for an attorney's fees award under § 1132(g)(1), but must show some degree of success on the merits.

A fee claimant need not be a 'prevailing party' to be eligible for an attorney's fees award under § 1132(g)(1), but must show some degree of success on the merits.

Analysis

The Supreme Court analyzed the language of § 1132(g)(1) and determined that it does not explicitly require a claimant to be a 'prevailing party' to receive attorney fees. Instead, the Court emphasized that a claimant must demonstrate 'some degree of success on the merits.' In Hardt's case, the District Court found compelling evidence of her total disability and remanded the case for further review, which ultimately led to the award of benefits. This constituted sufficient success on the merits to justify the award of attorney fees.

The Supreme Court analyzed the language of § 1132(g)(1) and determined that it does not explicitly require a claimant to be a 'prevailing party' to receive attorney fees.

Conclusion

The Supreme Court reversed the Fourth Circuit's decision and remanded the case, affirming that Hardt was entitled to attorney fees under ERISA's fee-shifting statute.

The Supreme Court reversed the Fourth Circuit's decision and remanded the case, affirming that Hardt was entitled to attorney fees under ERISA's fee-shifting statute.

Who won?

Bridget Hardt prevailed in the case because the Supreme Court ruled that she achieved some success on the merits, which justified the award of attorney fees.

Bridget Hardt prevailed in the case because the Supreme Court ruled that she achieved some success on the merits, which justified the award of attorney fees.

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