Thank You For Submiting Feedback!
Supreme Court of the United States
April 26, 2010, Argued; May 24, 2010, Decided
[***1003] [**2152] Justice Thomas [****6] delivered the opinion of the Court.
In most lawsuits seeking relief under the Employee Retirement Income Security Act of 1974 (ERISA), 88 Stat. 829, as amended, 29 U.S.C. § 1001 et seq., “a reasonable attorney's fee and costs” are available “to either party” at the court's “discretion.” § 1132(g)(1). The Court of Appeals for the Fourth Circuit has interpreted § 1132(g)(1) to require that a fee claimant be a “prevailing party” before he may seek a fees award. We reject this interpretation as contrary [*245] to § 1132(g)(1)'s plain text. We hold instead that a court “in its discretion” may award fees and costs “to either party,” ibid., as long as the fee claimant has achieved “some degree of success on the merits,” Ruckelshaus v. Sierra Club, 463 U.S. 680, 694, 103 S. Ct. 3274, 77 L. Ed. 2d 938 (1983).
In 2000, while working as an executive assistant to the president of textile manufacturer Dan River, Inc., petitioner Bridget Hardt began experiencing neck and shoulder pain. Her doctors eventually diagnosed her with carpal tunnel syndrome. Because surgeries on both her wrists failed to alleviate her pain, Hardt stopped working in January 2003.
In August 2003, Hardt sought long-term disability benefits from Dan River's Group Long-Term [****7] Disability Insurance Program Plan (Plan). Dan River administers the Plan, which is subject to ERISA, but respondent Reliance Standard Life Insurance Company decides whether a claimant qualifies for benefits under the Plan and underwrites any benefits awarded. Reliance provisionally approved Hardt's claim, telling her that final approval hinged on her performance in a functional capacities evaluation intended to assess the impact of her carpal tunnel syndrome and neck pain on her ability to work.
Hardt completed the functional capacities evaluation in October 2003. The evaluator summarized Hardt's medical history, observed her resulting physical limitations, and ultimately found that Hardt could perform some amount of sedentary work. Based on this finding, Reliance concluded that Hardt was not totally disabled within the meaning of the Plan and denied her claim for disability benefits. Hardt filed an administrative appeal. Reliance reversed itself in part, finding that Hardt was totally disabled from her regular occupation, and was therefore entitled to temporary disability benefits for 24 months.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
560 U.S. 242 *; 130 S. Ct. 2149 **; 176 L. Ed. 2d 998 ***; 2010 U.S. LEXIS 4164 ****; 78 U.S.L.W. 4448; 49 Employee Benefits Cas. (BNA) 1001; 22 Fla. L. Weekly Fed. S 351
BRIDGET HARDT, Petitioner v. RELIANCE STANDARD LIFE INSURANCE COMPANY
Prior History: [****1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT.
Hardt v. Reliance Std. Life Ins. Co., 336 Fed. Appx. 332, 2009 U.S. App. LEXIS 15478 (4th Cir. Va., 2009)
Disposition: Reversed and remanded.
attorney's fees, prevailing party, benefits, district court, claimant, pain, disability benefits, fees award, merits, total disability, neuropathy, evaluator, eligible, costs, long-term
Pensions & Benefits Law, Damages, Costs & Attorney Fees, Court Costs, Discretionary Fees, Governments, Legislation, Interpretation, Civil Procedure, Attorney Fees & Expenses, Basis of Recovery, American Rule, Statutory Awards, Judicial Officers, Judges, Discretionary Powers