Supreme Court Holds that ERISA Does Not Impose “Prevailing Party” Requirement for Award of Attorneys’ Fees


The U.S. Supreme Court ruled today in Hardt v. Reliance Standard Life Insurance Company, Case. No 09-448 (May 24, 2010), that the Employee Retirement Income Security Act of 1974 (ERISA) does not impose a “prevailing party” requirement for an award of statutory attorneys’ fees and costs in most ERISA cases. The fee claimant, however, must show “some degree of success on the merits.”

In this case, the plaintiff, Hardt, sought benefits under her employer’s ERISA-governed, long-term disability plan (Plan). The claims administrator initially determined that Hardt was not disabled as defined by the Plan and denied her claim for benefits. The claims administrator then reversed its decision on administrative appeal, awarding benefits to Hardt for a 24-month period. After the initial 24-month period, the Plan imposed a more stringent definition of disability. The claims administrator determined that Hardt could not meet this definition and denied her claim for benefits after the initial 24-month period had expired. The claims administrator upheld this decision on administrative appeal, and Hardt filed suit seeking benefits. The United States District Court for the Eastern District of Virginia denied cross-motions for summary judgment and remanded the claim for further administrative review. On remand, the claims administrator ultimately determined that Hardt was disabled as defined by the Plan and awarded long-term disability benefits.

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