Hardt v. Reliance Standard Life Insurance
The Court ruled that a worker seeking attorney's fees under a federal employee-benefits law does not have to prove she was the outright winner of her lawsuit. Instead, she only needs to show she achieved some real success on the merits of her claim.
The decision rejects a stricter test some lower courts had used and gives judges broader discretion to award fees whenever a worker's lawsuit meaningfully moved the needle, even through a court-ordered do-over rather than a final win.
How it got here: A district court remanded Hardt's benefits claim to the insurer and later awarded her fees; the Fourth Circuit vacated the fee award, and she sought Supreme Court review.
The Case in Depth
What happened
Bridget Hardt, an executive assistant, developed carpal tunnel syndrome and later neuropathy that left her unable to work. Her employer's insurer, Reliance Standard Life Insurance Company, repeatedly denied and then limited her long-term disability benefits under a company benefits plan governed by federal law. After a court found the insurer's review inadequate and ordered it to reconsider, the insurer reversed course and paid her benefits.
The question before the Court
Can a disabled worker get attorney's fees from her insurer under a federal pension-and-benefits law even though she never technically won her case outright?
Why it matters
Millions of workers who sue their employers or insurers over denied pension and disability benefits under this law will find it easier to recover their attorney's fees, even when their case ends in a court-ordered second look rather than an outright victory. This lowers the financial risk of challenging benefit denials.
What changes now
This is a final merits decision. The case returns to the lower courts for further proceedings consistent with the ruling, meaning the fee award to Hardt should be reinstated under the correct legal standard. The Court left open whether a bare remand order alone, without the additional favorable findings present here, would be enough to satisfy the 'some success' standard in future cases.
What this does not decide
The Court did not decide whether a remand order by itself, without more, is enough to count as 'some success on the merits.' It resolved only this case, where the remand was paired with strong findings favoring Hardt and a resulting benefits award.
Concurrences and dissents
Concurrence — Justice Stevens
Justice Stevens joined the judgment and the statutory-text portions of the opinion but objected to relying heavily on the Court's earlier Clean Air Act fee-shifting decision, which he thought was wrongly decided based on a contested reading of legislative history. He would examine each fee-shifting statute's own text, structure, and history rather than assuming Congress meant the same approach across different statutes.
How the Court got there
The legal reasoning, step by step
- The Court began with the text of the fee-shifting provision, which lets a court award attorney's fees 'in its discretion' 'to either party,' without ever using the phrase 'prevailing party.'
- Comparing this provision to a neighboring one that does require a party to win 'a judgment in favor of the plan,' the Court concluded Congress knows how to write a prevailing-party requirement when it wants one, and chose not to here.
- Because the lower court's 'prevailing party' requirement was not in the statute's text, the Court held it improperly added a term to the law rather than interpreting the law Congress actually wrote.
- Turning to what standard should apply instead, the Court relied on its approach in a prior case interpreting a similarly worded fee-shifting provision in the Clean Air Act, which asked only whether a claimant achieved 'some degree of success on the merits' — a lower bar than being an outright winner.
- Applying that same some-success standard here, the Court found that the district court's finding of 'compelling evidence' that Hardt was disabled, its expressed inclination to rule for her, and its court-ordered do-over that led the insurer to reverse itself and pay her benefits, together amounted to far more than trivial or merely procedural success.
Doctrinal impact
Cases affected by this decision
Reaffirms Ruckelshaus v. Sierra Club (463 U. S. 680)
The Court relies on this case's 'some degree of success on the merits' standard to interpret the ERISA fee provision.