holding that plaintiff, whose claim for benefits was denied by insurer, achieved some success on the merits of her ERISA claim when, although the plaintiff “failed to win summary judgment on her benefits claim, the [d]istrict [c]ourt nevertheless found ‘compelling evidence’” that supported her case and stated that it was inclined to grant her summary judgment but first ordered the insurer to reconsider her claim and the insurer, during its “court- ordered review,” awarded the plaintiff the claimed benefits
How later courts described this case
- holding that plaintiff, whose claim for benefits was denied by insurer, achieved some success on the merits of her ERISA claim when, although the plaintiff “failed to win summary judgment on her benefits claim, the [d]istrict [c]ourt nevertheless found ‘compelling evidence’” that supported her case and stated that it was inclined to grant her summary judgment but first ordered the insurer to reconsider her claim and the insurer, during its “court- ordered review,” awarded the plaintiff the claimed benefits
- holding provision of the Patent Act that requires applicants who file action in federal court to pay “[a]ll expenses of the proceeding,” 35 U.S.C. § 145 , does not overcome the American Rule’s presumption against fee shifting to permit the Patent and Trademark Office to recover attorneys’ fees
- finding that the plaintiff was entitled to attorney’s fees after a finding that “the plan administrator . . . failed to comply with ERISA guidelines” and remanded the plaintiff's case back to the plan administrator who reversed its decision and awarded the plaintiff “the benefits she sought”
- holding that “purely procedural victories]” do not qualify for fees even under standards “less stringent” than the prevailing-party requirement
Written by the judges who cited it.
The opinion
SEPARATE OPINION
[ 560 U.S. 257 ]
Justice Stevens,
concurring in part and concurring in the judgment.
While I join the Court’s judgment and Parts I and II of its opinion, I do not believe that our mistaken interpretation of § 307(f) of the Clean Air Act in Ruckelshaus v. Sierra Club, 463 U.S. 680 , 103 S. Ct. 3274 , 77 L. Ed. 2d 938 (1983), should be given any special weight in the interpretation of this—or any other—different statutory provision. The outcome in that closely divided case turned, to a significant extent, on a judgment about how to read the legislative history of the provision in question. Compare id., at 686-693 , 103 S. Ct. 3274 , 77 L. Ed. 2d 938 , with id., at 703-706 , 103 S. Ct. 3274 , 77 L. Ed. 2d 938 (Stevens, J., dissenting). I agree with the Court in this case that 29 U.S.C. § 1132 (g)(1) does not impose a “pre *1011 vailing party” requirement; I agree, further, that the District Court acted well within its discretion in awarding attorney’s fees to this petitioner. But I would examine the text, structure, and history of any other federal statute authorizing an award of fees before concluding that Congress intended the same approach under that statute as under this one.