Hardt v. Reliance Standard Life Insurance Co.
The Court ruled that a worker seeking attorney's fees under ERISA's fee-shifting provision does not have to be a formal "prevailing party" in her lawsuit — she only needs to show some degree of success on the merits of her claim.
Because a disability claimant who won a court-ordered do-over of her benefits review, and then actually received the benefits, had achieved that kind of success, the Court reinstated the fee award a lower appeals court had thrown out.
How it got here: After a federal trial court awarded Hardt attorney's fees, the Fourth Circuit vacated that award for lack of prevailing-party status, and Hardt asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Bridget Hardt worked as an executive assistant until neck, shoulder, and later foot and leg pain from carpal tunnel syndrome and neuropathy forced her to stop. She sought long-term disability benefits from her employer's ERISA plan, administered by Reliance Standard Life Insurance Company. Reliance initially paid temporary benefits but later cut them off, concluding she was not "totally disabled" under the plan's stricter long-term standard.
The question before the Court
Can a worker who sues her employer's disability insurer under ERISA recover attorney's fees even if she never technically "won" the lawsuit outright?
Why it matters
Employees who fight insurance companies or plan administrators over denied disability, health, or pension benefits under ERISA often win partial victories — like a court order sending their claim back for a fairer review — without winning a final courtroom judgment. This ruling makes it easier for those workers to recover their attorney's fees even without a formal court win, reducing the financial risk of challenging benefit denials.
What changes now
The Supreme Court reversed the Fourth Circuit's ruling that had thrown out the fee award, and sent the case back for further proceedings consistent with its opinion. Because the Court found Hardt had already shown enough success on the merits to qualify for fees, the practical effect is that her original fee award, granted by the district court, is restored. The Court left open whether a bare remand order alone, without an eventual benefits award, would be enough to qualify a claimant for fees in future cases.
What this does not decide
The Court expressly did not decide whether a court order sending a claim back for reconsideration, by itself and without more, is enough to count as "some success on the merits." It resolved only Hardt's case, where the remand was followed by an actual award of benefits.
Concurrences and dissents
Concurrence — Justice Stevens
Justice Stevens joined the judgment and the first two parts of the majority opinion but refused to endorse relying on the Court's earlier Clean Air Act fee decision as a template for this ERISA case. He argued that decision was itself closely divided and rested heavily on a debatable reading of legislative history, and urged that any other fee statute's text, structure, and history be independently examined rather than assuming the same approach applies across different laws.
How the Court got there
The legal reasoning, step by step
- The Court first examined the text of ERISA's fee provision, 29 U.S.C. § 1132(g)(1), which lets a court in its discretion award fees "to either party" and never mentions a "prevailing party" requirement, unlike a neighboring ERISA provision that explicitly demands a favorable judgment.
- Because Congress knew how to write an express prevailing-party limit elsewhere in the same law but didn't do so here, the Court concluded that reading such a requirement into this provision would be inventing a statute rather than interpreting one.
- Turning to what standard should apply instead, the Court looked to its earlier decision in a Clean Air Act case that also lacked a prevailing-party requirement, which held that a fee claimant must show "some degree of success on the merits" — meaning more than a trivial or purely procedural win — before a court may use its discretion to award fees.
- The Court rejected the lower appeals court's five-factor test for ERISA fee awards, since those factors had no clear connection to the statute's text or to the Court's fee-shifting precedents, and were therefore not required.
- Applying the some-success standard to the facts, the Court found that persuading a trial judge that the insurer had failed to give her claim the fair review ERISA requires, obtaining a court order forcing a proper review, and then actually receiving the disability benefits, together amounted to real success on the merits — not a merely trivial or procedural victory.
Doctrinal impact
Cases affected by this decision
Reaffirms Ruckelshaus v. Sierra Club (463 U.S. 680)
The Court relied on this Clean Air Act fees case as the model for the 'some success on the merits' standard applied here.
Distinguishes Buckhannon Board & Care Home, Inc. v. West Virginia Dept. of Health and Human Resources (532 U.S. 598)
The Court said this prevailing-party precedent does not govern fee awards under ERISA's differently worded fee statute.