Justices make it easier for employees to win legal fees in disability cases

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Legal Times article

Workers suing over disability and other benefits under the federal law known as ERISA may win attorney fees and costs if they achieve "some degree of success on the merits," a unanimous U.S. Supreme Court ruled on Monday.

In Hardt v. Reliance Standard Life Insurance Co., the justices rejected a tougher standard imposed by the U.S. Court of Appeals for the 4th Circuit on fee claimants under the Employee Retirement and Income Security Act. The lower appellate court had ruled that a claimant must be a "prevailing party" before seeking a fee award.

The justices' ruling came in a case brought by Bridget Hardt, who sought long-term disability benefits as a result of job-related carpal tunnel syndrome. Hardt was awarded the benefits, but in March 2006, Reliance informed her that she was ineligible for continued long-term benefits. She sued the insurance company, claiming ERISA violations.

http://www.law.com/jsp/nlj/PubArticleNLJ.jsp?id=1202458687542&Justices_make_it_easier_for_employees_to_win_legal_fees_in_disability_cases


The 4th Circuit Judges who are responsible for the former result

Wilkinson, James Harvie III, Nominated by Ronald Reagan on January 30, 1984 (once interviewed by Bush for SCOTUS)
Faber, David A., Nominated by George H.W. Bush on August 1, 1991 (District Judge, sitting by designation).

http://pacer.ca4.uscourts.gov/opinion.pdf/081896.U.pdf


SCOTUS Decision

THOMAS, J., delivered the opinion of the Court (assigned by Roberts), in which ROBERTS, C. J., and SCALIA, KENNEDY, GINSBURG, BREYER, ALITO, and SOTOMAYOR, JJ., joined, and in which STEVENS, J., joined as to Parts I and II. STE-VENS, J., filed an opinion concurring in part and concurring in the judgment.

Opinion of the Court:

These facts establish that Hardt has achieved far more than “trivial success on the merits” or a “purely procedural victory.” Accordingly, she has achieved “some success on the merits,” and the District Court properly exercised its discretion to award Hardt attorney’s fees in this case.Because these conclusions resolve this case, we need not decide today whether a remand order, without more, constitutes “some success on the merits” sufficient to make a party eligible for attorney’s fees under §1132(g)(1).9

* * * We reverse the judgment of the Court of Appeals for the Fourth Circuit and remand this case for proceedings consistent with this opinion.
It is so ordered.

JUSTICE STEVENS, concurring in part and concurring in the judgment:

While I join the Court’s judgment and Parts I and II of its opinion, I do not believe that our mistaken interpretation of §307(f) of the Clean Air Act in Ruckelshaus v. Sierra Club, 463 U. S. 680 (1983), should be given any special weight in the interpretation of this—or any other—different statutory provision. The outcome in that closely divided case turned, to a significant extent, on a judgment about how to read the legislative history of the provision in question. Compare id., at 686–693, with id., at 703–706 (STEVENS, J., dissenting). I agree with the Court in this case that 29 U. S. C. §1132(g)(1) does not impose a “prevailing party” requirement; I agree, further, that the District Court acted well within its discretion in awarding attorney’s fees to this petitioner. But I would examine the text, structure, and history of any other federal statute authorizing an award of fees before concluding that Congress intended the same approach under that statute asunder this one.

http://www.supremecourt.gov/opinions/09pdf/09-448.pdf