Attorney’s Fees Awarded to Plaintiff in ERISA Disability Case
In an ERISA disability case in Chicago, a federal district court judge awarded attorney’s fees of $109,312.75 to the successful complainant, Ms. Holmstrom. After MetLife made the decision to terminate her claim for long term disability benefits, she sued MetLife and her employer’s benefit plan.
Holmstrom willingly discharged her own lawsuit after MetLife offered to consider her second internal appeal. However, after MetLife declined to change its mind, she re-filed her case. After the district court agreed with MetLife’s decision to terminate her claim, she appealed to the 7th Circuit Court of Appeals.
The appeals court reversed the judge and ruled in Holmstrom’s favor. The appeals court found that MetLife had acted arbitrarily and capriciously. The appeals court reinstated Holmstrom’s disability payments benefits but then left the issue of attorney’s fees for the district court to decide.
The court noted that the U.S. Supreme recently ruled, in a case called Hardt, that ERISA’s legal fee provisions allow fees to be awarded to an ERISA litigant who has achieved “some success” on the merits. The court said that Hardt supplanted the 7th Circuit’s standard for ERISA fee awards. The district court ruled that Holmstrom had achieved more than some quantity of success on the merits since the 7th Circuit had reinstated her disability insurance benefits.
