Hardt v. Reliance Standard Life Insurance Co.

Background

Bridget Hardt was an executive assistant at a textile company who sought long term disability benefits under her employer's ERISA plan. The insurer Reliance Standard initially denied that she was totally disabled after reviewing functional evaluations, then reversed itself to grant temporary benefits for twenty four months. Hardt later won Social Security disability benefits. After further review and a court-ordered remand, Reliance awarded Hardt past due long term benefits, and she sought attorney fees under ERISA.

Reasoning

The Court addressed whether 29 U.S.C. section 1132(g)(1) requires a claimant to be a formal 'prevailing party' before a judge can award attorney fees. Relying on the statute's plain text, the Court rejected the Fourth Circuit's rule and held that courts may award fees in their discretion if the claimant has achieved some degree of success on the merits, following Ruckelshaus. Applying that standard, the Court found Hardt's court order and Reliance's later award of benefits showed more than trivial success, so fees were properly awarded.

Real world impact

This ruling makes it easier for people who obtain meaningful relief against plan administrators to recover attorney fees even without an outright victory. Judges retain discretion and may consider factors about fairness and the reasonableness of fees. The Court did not decide whether a remand alone always qualifies as some success on the merits, so that question may arise in later cases affecting employers, insurers, and benefit claimants.

Dissents or concurrances

Justice Stevens joined the judgment but cautioned that Ruckelshaus should not be treated as controlling for different fee statutes and said each statute's text and history should be examined separately.