Hardt v. Reliance Standard Life Ins. Co.

Citation130 S.Ct. 2149,176 L.Ed.2d 998,560 U.S. 242
Decision Date24 May 2010
Docket NumberNo. 09–448.,09–448.
CourtUnited States Supreme Court

John R. Ates

, Alexandria, VA, for petitioner.

Pratik A. Shah

, for the United States as amicus curiae, by special leave of the Court, supporting the petitioner.

Nicholas Q. Rosenkranz, Washington, DC, for respondent.

Ann K. Sullivan

, Elaine Inman Hogan, Crenshaw, Ware & Martin, P.L.C., Norfolk, VA, John R. Ates, Counsel of Record, Ates Law Firm, P.C., Alexandria, VA, for petitioner.

Nicholas Quinn Rosenkranz, Washington, DC, Howard M. Radzely

, Richard W. Black, Danny E. Petrella, Morgan, Lewis & Bockius LLP, Washington, DC, R. Ted Cruz, Counsel of Record, Morgan, Lewis & Bockius LLP, Houston, TX, A. Lauren Carpenter, Morgan, Lewis & Bockius LLP, Philadelphia, PA, for respondent.Opinion

Justice THOMAS

delivered the opinion of the Court.

In most lawsuits seeking relief under the Employee Retirement Income Security Act of 1974 (ERISA), 88 Stat. 829, as amended, 29 U.S.C. § 1001 et seq.,

“a reasonable attorney's fee and costs” are available “to either party at the court's “discretion.” § 1132(g)(1). The Court of Appeals for the Fourth Circuit has interpreted § 1132(g)(1) to require that a fee claimant be a “prevailing party before he may seek a fees award. We reject this interpretation as contrary to § 1132(g)(1)

's plain text. We hold instead that a court “in its discretion” may award fees and costs “to either party,” ibid., as long as the fee claimant has achieved “some degree of success on the merits,” Ruckelshaus v. Sierra Club, 463 U.S. 680, 694, 103 S.Ct. 3274, 77 L.Ed.2d 938 (1983).


In 2000, while working as an executive assistant to the president of textile manufacturer Dan River, Inc., petitioner Bridget Hardt began experiencing neck and shoulder pain. Her doctors eventually diagnosed her with carpal tunnel syndrome

. Because surgeries on both her wrists failed to alleviate her pain, Hardt stopped working in January 2003.

In August 2003, Hardt sought long-term disability benefits from Dan River's Group Long–Term Disability Insurance Program Plan (Plan). Dan River administers the Plan, which is subject to ERISA, but respondent Reliance Standard Life Insurance Company decides whether a claimant qualifies for benefits under the Plan and underwrites any benefits awarded. Reliance provisionally approved Hardt's claim, telling her that final approval hinged on her performance in a functional capacities evaluation intended to assess the impact of her carpal tunnel syndrome

and neck pain on her ability to work.

Hardt completed the functional capacities evaluation in October 2003. The evaluator summarized Hardt's medical history, observed her resulting physical limitations, and ultimately found that Hardt could perform some amount of sedentary work. Based on this finding, Reliance concluded that Hardt was not totally disabled within the meaning of the Plan and denied her claim for disability benefits. Hardt filed an administrative appeal. Reliance reversed itself in part, finding that Hardt was totally disabled from her regular occupation, and was therefore entitled to temporary disability benefits for 24 months.

While her administrative appeal was pending, Hardt began experiencing new symptoms in her feet and calves, including tingling, pain, and numbness. One of her physicians diagnosed her with small-fiber neuropathy

, a condition that increased her pain and decreased her physical capabilities over the ensuing months.

Hardt eventually applied to the Social Security Administration for disability benefits under the Social Security Act. Her application included questionnaires completed by two of her treating physicians, which described Hardt's symptoms and stated the doctors' conclusion that Hardt could not return to full gainful employment because of her neuropathy

and other ailments. In February 2005, the Social Security Administration granted Hardt's application and awarded her disability benefits.

About two months later, Reliance told Hardt that her Plan benefits would expire at the end of the 24–month period. Reliance explained that under the Plan's terms, only individuals who are “totally disabled from all occupations” were eligible for benefits beyond that period, App. to Pet. for Cert. 36a, and adhered to its conclusion that, based on its review of Hardt's records, Hardt was not “totally disabled” as defined by the Plan. Reliance also demanded that Hardt pay Reliance $14,913.23 to offset the disability benefits she had received from the Social Security Administration. (The Plan contains a provision coordinating benefits with Social Security payments.) Hardt paid Reliance the offset.

Hardt then filed another administrative appeal. She gave Reliance all of her medical records, the questionnaires she had submitted to the Social Security Administration, and an updated questionnaire from one of her physicians. Reliance asked Hardt to supplement this material with another functional capacities evaluation. When Reliance referred Hardt for the updated evaluation, it did not ask the evaluator to review Hardt for neuropathic pain, even though it knew that Hardt had been diagnosed with neuropathy

after her first evaluation.

Hardt appeared for the updated evaluation in December 2005, and appeared for another evaluation in January 2006. The evaluators deemed both evaluations invalid because Hardt's efforts were “submaximal.” Id., at 37a. One evaluator recorded that Hardt “refused multiple tests ... for fear of nausea/illness/further pain complaints.” Ibid. (internal quotation marks omitted).

Lacking an updated functional capacities evaluation, Reliance hired a physician and a vocation rehabilitation counselor to help it resolve Hardt's administrative appeal. The physician did not examine Hardt; instead, he reviewed some, but not all, of Hardt's medical records. Based on that review, the physician produced a report in which he opined that Hardt's health was expected to improve. His report, however, did not mention Hardt's pain medications or the questionnaires that Hardt's attending physicians had completed as part of her application for Social Security benefits. The vocational rehabilitation counselor, in turn, performed a labor market study (based on Hardt's health in 2003) that identified eight employment opportunities suitable for Hardt. After reviewing the physician's report, the labor market study, and the results of the 2003 functional capacities evaluation, Reliance concluded that its decision to terminate Hardt's benefits was correct. It advised Hardt of this decision in March 2006.

After exhausting her administrative remedies, Hardt sued Reliance in the United States District Court for the Eastern District of Virginia. She alleged that Reliance violated ERISA by wrongfully denying her claim for long-term disability benefits. See § 1132(a)(1)(B)

. The parties filed cross-motions for summary judgment, both of which the District Court denied.

The court first rejected Reliance's request for summary judgment affirming the denial of benefits, finding that “Reliance's decision to deny benefits was based on incomplete information.” App. to Pet. for Cert. 42a. Most prominently, none of the functional capacities evaluations to which Hardt had submitted had “assessed the impact of neuropathy

and neuropathic pain on Ms. Hardt.” Ibid. In addition, the reviewing physician's report “was itself incomplete”; the basis for the physician's “medical conclusions [wa]s extremely vague and conclusory,” ibid., and the physician had “failed to cite any medical evidence to support his conclusions,” id., at 43a, or “to address the treating physicians' contradictory medical findings,” id., at 44a. The court also found that Reliance had “improperly rejected much of the evidence that Ms. Hardt submitted,” id., at 45a, and had “further ignored the substantial amount of pain medication Ms. Hardt's treating physicians had prescribed to her,” id., at 46a. Accordingly, the court thought it “clear that Reliance's decision to deny Ms. Hardt long-term disability benefits was not based on substantial evidence.” Id., at 47a.

The District Court then denied Hardt's motion for summary judgment, which contended that Reliance's decision to deny benefits was unreasonable as a matter of law. In so doing, however, the court found “compelling evidence” in the record that “Ms. Hardt [wa]s totally disabled due to her neuropathy

.” Id., at 48a. Although it was “inclined to rule in Ms. Hardt's favor,” the court concluded that “it would be unwise to take this step without first giving Reliance the chance to address the deficiencies in its approach.” Ibid. In the District Court's view, a remand to Reliance was warranted because [t]his case presents one of those scenarios where the plan administrator has failed to comply with the ERISA guidelines,” meaning “Ms. Hardt did not get the kind of review to which she was entitled under applicable law.” Ibid. Accordingly, the court instructed “Reliance to act on Ms. Hardt's application by adequately considering all the evidence” within 30 days; [o]therwise,” it warned, “judgment will be issued in favor of Ms. Hardt.” Id., at 49a.

Reliance did as instructed. After conducting that review, Reliance found Hardt eligible for long-term disability benefits and paid her $55,250 in accrued, past-due benefits.

Hardt then moved for attorney's fees and costs under § 1132(g)(1)

. The District Court assessed her motion under the three-step framework that governed fee requests in ERISA cases under Circuit precedent. At step one of that framework, a district court asks whether the fee claimant is a ‘prevailing party.’ Id., at 15a–16a (quoting Martin v. Blue Cross & Blue Shield of Virginia, Inc., 115 F.3d 1201, 1210 (C.A.4 1997), and citing Buckhannon Board & Care Home, Inc. v. West Virginia Dept. of Health and Human Resources, 532 U.S. 598, 603, 121...

To continue reading

Request your trial
1172 cases
  • O.A. v. Trump
    • United States
    • U.S. District Court — District of Columbia
    • August 2, 2019
    ...(2016), and "must enforce plain and unambiguous statutory language according to its terms," Hardt v. Reliance Standard Life Ins. Co. , 560 U.S. 242, 251, 130 S.Ct. 2149, 176 L.Ed.2d 998 (2010). As the Supreme Court "ha[s] stated time and again[,] ... courts must presume that a legislature s......
  • Kennedy v. Carnival Corp.
    • United States
    • U.S. District Court — Southern District of Florida
    • March 6, 2019
    ...omitted). "If the statutory language is plain, we must enforce it according to its terms." Hardt v. Reliance Standard Life Ins. Co. , 560 U.S. 242, 251, 130 S.Ct. 2149, 176 L.Ed.2d 998 (2010). But often the "meaning – or ambiguity – of certain words or phrases may only become evident when p......
  • Madoff v. Amaral (In re Amaral)
    • United States
    • U.S. Bankruptcy Court — District of Massachusetts
    • May 8, 2017
    ...pays his own attorney's fees, win or lose, unless a statute or contract provides otherwise." Hardt v. Reliance Standard Life Ins. Co. , 560 U.S. 242, 252–253, 130 S.Ct. 2149, 176 L.Ed.2d 998 (2010) (internal quotation marks omitted). The American Rule has roots in our common law reaching ba......
  • Tussey v. ABB, Inc., Case No. 06-04305-CV-C-NKL
    • United States
    • U.S. District Court — Western District of Missouri
    • November 2, 2012
    ...show some degree of success on the merits before a court may award attorney's fees under § 1132(g)(1)," Hardt v. Reliance Standard Life Ins. Co., 130 S. Ct. 2149, 2158, 176 (2010) (internal quotes omitted), a fee award "should not be reduced merely because a party did not prevail on every t......
  • Request a trial to view additional results
6 firm's commentaries
  • ERISA Newsletter - 1st Quarter 2013 - Volume 4, Number 1
    • United States
    • Mondaq United States
    • April 24, 2013
    ...recovery of his legal fees under ERISA section 1132(g)(1) and the Supreme Court's holding Hardt v. Reliance Standard Life Ins. Co., 130 S. Ct. 2149. The Court declined to opine on whether the previous test used to award attorney fees survived Hardt, and found that the district court erroneo......
  • The ERISA Litigation Newsletter – May 2014
    • United States
    • Mondaq United States
    • May 23, 2014
    ...for evaluating an ERISA attorneys' fee application following the U.S. Supreme Court's ruling in Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242 (2010). As previously reported, in Hardt, the Supreme Court observed that ERISA's fee shifting provision unambiguously allows a court to awa......
  • The 'American Rule' Prevails: The Supreme Court Denies Certain Fees In Bankruptcy Cases
    • United States
    • Mondaq United States
    • July 4, 2015
    ...pays his own attorney's fees, win or lose, unless a statute or contract provides otherwise." Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242 (2010). Under §327(a), professionals are retained to serve the administrator of the estate for the benefit of the estate. Compensation authoriz......
  • Supreme Court Rules Against Fees For Fee Application Defense
    • United States
    • Mondaq United States
    • June 21, 2015
    ...one other potentially significant hint. In describing the American Rule, Justice Thomas quotes Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242, 252-53 (2010), stating: "Each litigant pays his own attorney's fees, win or lose, unless a statute or contract provides otherwise" (emphasis......
  • Request a trial to view additional results
6 books & journal articles
  • Chapter §20.06 Attorney Fees in Exceptional Cases
    • United States
    • Full Court Press Mueller on Patent Law Volume II: Patent Enforcement Title CHAPTER 20 Remedies for Patent Infringement
    • Invalid date
    ...84 (2013).[864] NantKwest, Inc. v. Iancu, 898 F.3d 177, 1181 (Fed. Cir. 2018) (en banc) (quoting Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242, 253 (2010)).[865] NantKwest, 898 F.3d at 1181 (citing Baker Botts L.L.P. v. ASARCO LLC, 135 S. Ct. 2158, 2164 (2015)).[866] NantKwest, 898......
  • How to litigate an Erisa disability claim
    • United States
    • James Publishing Practical Law Books Erisa disability. Claims and litigation Content
    • May 6, 2021
    ...circumstances under which a court should exercise its “discretion.” Because this 7 See, e.g., Hardt v. Reliance Standard Life Ins. Co. , 560 U.S. 242, 253 (2010) (“Most fee-shifting provisions permit a court to award attorney’s fees only to a ‘prevailing party.’”). 10-175 How to Litigate an......
  • Fee-Shifting in Bankruptcy.
    • United States
    • American Bankruptcy Law Journal Vol. 95 No. 4, December 2021
    • December 22, 2021
    ...Darling Law Library, in particular Rebecca Fordon, Esq. (1) 576 U.S. 121, 126 (2015) (quoting Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242, 252-53 (2010)). Justice Sotomayor concurred writing: "Given the clarity of the statutory language, it would be improper to allow policy consi......
  • Student Loan Bankruptcy and the Meaning of Educational Benefit.
    • United States
    • American Bankruptcy Law Journal Vol. 93 No. 2, March 2019
    • March 22, 2019
    ...1850, 1856 (2016) ("Statutory interpretation, as we always say, begins with the text." (citing Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242, 251 (2010))). As Justice Frankfurter's "three-fold imperative to law students" goes, "(1) Read the statute; ?(2) read the statute; ?(3) read......
  • Request a trial to view additional results

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT