In a suit against an employer under ERISA, a plaintiff may seek an award of attorneys' fees if she is a prevailing party, and the Fourth Circuit ruled that a plaintiff must receive "at least some relief on the merits" of a claim to be a prevailing party. In this case, a woman claimed disability benefits for carpal-tunnel syndrome, but was denied. She filed a complaint, and the court, while not providing a benefits award or an enforceable judgment, found that the denial was not based on substantial evidence, and ordered the insurance company to reconsider the claim. It did, and eventually paid the benefits.
The Supreme Court decided 5/24/10 that the statute does not require a party to be a prevailing party to be entitled to attorneys' fees. This statute is different from others in that it allows a court to award fees to either party in its discretion. This discretion is guided by the Court's ruling that the party must have obtained "some degree of success on the merits." The plaintiff did so in this case and was awarded attorneys' fees. The case is significant for manufacturers, who pay for ERISA benefits, because awards of attorneys' fees increase the cost of providing benefits.