Supreme Court of the United States

Hardt v. Reliance Standard Life Insurance Co.

May 24, 2010560 U.S. 242

Summary

The Supreme Court held that a fee claimant need not be a 'prevailing party' to recover attorney's fees under ERISA §1132(g)(1). Instead, fees may be awarded where the claimant achieves some degree of success on the merits. Justice Stevens concurred, agreeing on the outcome but cautioning against extending the Ruckelshaus rationale to other statutes.

Holding

  • Eligibility for attorney's fees under §1132(g)(1). A fee claimant need not be a 'prevailing party' to be eligible for an attorney's fees award under §1132(g)(1).
  • Standard for awarding attorney's fees under §1132(g)(1). A court may award fees and costs under §1132(g)(1) as long as the fee claimant has achieved 'some degree of success on the merits.'

Docket 09-448

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