Term: 2009
Docket: 09-448
Bridget Hardt v. Reliance Standard Life Insurance Company
- Pro
09-448 HARDT V. RELIANCE STANDARD LIFE INS. DECISION BELOW:336 Fed.Appx. 332 EXPEDITED BRIEFING SCHEDULE CERT. GRANTED 1/15/2010 QUESTIONS PRESENTED: Section 502(g)(1) of the Employee Retirement Income Security Act of 1974 (ERISA) provides: "In any action under this subchapter . . . by a participant, beneficiary, or fiduciary, the court in its discretion may allow a reasonable attorney's fee and costs of the action to either party." 29 U.S.C. § 1132(g)(1). The Fourth Circuit in the decision below held that "only a prevailing party is entitled to consideration for attorneys' fees in an ERISA action," while the Second, Fifth and Eleventh Circuits have declined to read a "prevailing party" requirement into § 502 (g)(1) and other circuits have issued conflicting authority. The Fourth Circuit also held that the "prevailing party" standard was not met and vacated an award of attorneys' fees to petitioner, even where the district court found "compelling evidence that [petitioner] is totally disabled," ruled that petitioner "did not get the kind of review to which she was entitled under applicable law" and remanded for a redetermination of benefits with an instruction that respondents "act on [petitioner's] application by adequately considering all the evidence discussed within this Opinion within thirty (30) days of its date of issuance" or "judgment will be issued in favor of [petitioner]" and petitioner obtained the requested long-term disability benefits upon remand. The questions presented are: 1. Whether the Fourth Circuit erred in holding that ERISA § 502(g)(1) provides a district court discretion to award reasonable attorney's fees only to a prevailing party? 2. Whether a party is entitled to attorney's fees pursuant to § 502(g)(1) when she persuades a district court that a violation of ERISA has occurred, successfully secures a judicially-ordered remand requiring a redetermination of entitlement to benefits and subsequently receives the benefits sought on remand? LOWER COURT CASE NUMBER: 08-1896
In the case of Bridget Hardt v. Reliance Standard Life Insurance Company, the Supreme Court ruled in favor of Ms. Hardt, who had been denied long-term disability benefits by her employer's insurance provider, Reliance Standard Life Insurance Company. The court held that a claimant can be awarded attorney’s fees if they achieve "some degree of success on the merits," even without a final judgment in their favor. This decision was based on an interpretation of ERISA (Employee Retirement Income Security Act), which allows courts to award attorney’s fees and costs to either party in lawsuits related to employee benefit plans. Prior to this ruling, many lower courts required claimants like Ms. Hardt to secure a final judgment or decree in their favor before being eligible for such awards.
In the dissenting opinion for Bridget Hardt v. Reliance Standard Life Insurance Company, Justice Ruth Bader Ginsburg disagreed with the majority's interpretation of ERISA (Employee Retirement Income Security Act). She argued that a court should not be able to award attorney’s fees under Section 1132(g)(1) unless the party seeking such fees has achieved "some degree of success on the merits." The majority ruled that Hardt was entitled to attorney's fees despite not having won her case outright; she had only received a remand order instructing Reliance Standard Life Insurance Company to reconsider its decision. According to Ginsburg, this did not constitute "success on the merits" and thus should not warrant an award of attorney’s fees. This interpretation, she contended, would lead courts astray from Congress' intent in drafting ERISA and could potentially open floodgates for fee claims by parties who have achieved minimal or inconclusive victories.
