Hardt v. Reliance Standard Life Insurance

Background

Bridget Hardt, a former textile company employee, stopped working because of pain and applied for long-term disability from her employer's ERISA-plan insurer, Reliance. After mixed administrative reviews and new medical evidence, Reliance denied continued benefits but then, after a court-ordered remand, reversed and paid past-due benefits. Hardt then asked the trial court for attorney’s fees under ERISA’s fee clause.

Reasoning

The Court addressed whether ERISA’s fee law requires a claimant to be a formal 'prevailing party' before receiving fees. The statute says courts, in their discretion, may award fees to either party. The Court held that the text does not demand a prevailing-party showing and instead adopted the rule that a fee award is allowable when a claimant has achieved 'some degree of success on the merits.' Because the District Court found compelling evidence of Hardt’s disability, ordered a review, and Reliance later paid benefits, Hardt met that standard.

Real world impact

The ruling means judges can award fees more flexibly in ERISA fights when a claimant achieves meaningful success, even without a formal judgment declaring them the winner. It permits courts to use the 'some success' standard rather than a strict 'prevailing party' test. The opinion leaves open specific applications, like whether a bare remand alone suffices, for lower courts to decide.

Dissents or concurrances

Justice Stevens joined the judgment but warned against relying too heavily on one earlier case when interpreting other statutes, urging courts to examine each fee law's text and history and to proceed cautiously.