Hardt v. Reliance Standard Life Insurance Co.

Summary

The Supreme Court held that ERISA § 1132(g)(1) does not require a fee claimant to be a 'prevailing party' to recover attorney’s fees. Instead, a court may award fees to any party achieving 'some degree of success on the merits.' The Court reversed the Fourth Circuit's vacatur of the fee award to Hardt, who achieved success through a remand order that led to benefit payments. Justice Stevens concurred in part and in the judgment, cautioning against extending Ruckelshaus reasoning to other statutes.