Martin v. Guardian Life Ins. Co. of Am.

Martin v. Guardian Life Ins. Co. of Am.

Opinion

MEMORANDUM OPINION AND ORDER

This matter came before the Court when Plaintiff William W. Martin filed an appeal of Guardian's denial of long-term disability benefits under a plan governed by the Employee Retirement Income Security Act ("ERISA"). The parties filed cross-motions for judgment and the Court ruled in favor of Guardian, finding that its decision to deny benefits was neither arbitrary nor capricious. [Record No. 69] Guardian has now filed a motion for attorneys' fees pursuant to 29 U.S.C. § 1132(g)(1), 28 U.S.C. § 1927, and Local Rule 54.4. [Record No. 73] Having reviewed the applicable considerations, Guardian's motion for attorneys' fees will be denied.

ERISA provides that, in any action brought under § 1132, "the court in its discretion may allow a reasonable attorney's fee and costs of action to either party." 29 U.S.C. § 1132(g)(1). The Court may award fees [*2]  and costs "as long as the fee claimant has achieved 'some degree of success on the merits.'" Hardt v. Reliance Standard Ins. Co., 560 U.S. 242, 245, 130 S. Ct. 2149, 176 L. Ed. 2d 998 (2010). While Guardian has achieved success on the merits, the Court's inquiry does not end there. The Court also considers the following factors in determining whether attorneys' fees should be granted under ERISA:

(1) the degree of the opposing party's culpability or bad faith; (2) the opposing party's ability to satisfy an award of attorney's fees; (3) the deterrent effect of an award on other persons under similar circumstances; (4) whether the party requesting fees sought to confer a common benefit on all participants and beneficiaries of an ERISA plan or resolve significant legal questions regarding ERISA; and (5) the relative merits of the parties' positions.

Sec'y of Dep't of Labor v. King, 775 F.2d 666, 669 (6th Cir. 1985). These factors are flexible and none is necessarily dispositive. See Moon v. Unum Provident Corp., 461 F.3d 639, 642-43 (6th Cir. 2006) (citing Schwartz v. Gregori, 160 F.3d 1116, 1119 (6th Cir. 1998)).

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