1 Lincoln Financial Co. v. Metropolitan Life Insurance
428 F. App'x 394
5th Cir.2011Background
- Lincoln sought ERISA benefits from MetLife arising from a life insurance policy; an assignment chain ran from the participant/beneficiary to a funeral home and then to Lincoln.
- MetLife denied the claim; Lincoln sued in state court, which MetLife removed to federal court; the district court granted MetLife summary judgment and Lincoln did not oppose.
- MetLife moved for attorney’s fees; the district court awarded Lincoln $17,842.21 in fees and costs.
- Lincoln appealed the fee award under ERISA; MetLife urged the district court’s discretion under Hardt and Bowen factors.
- The court held that a party can receive fees under §1132(g)(1) when there is some degree of success and district courts may consider, but need not apply, Bowen factors; the assignee stands in the shoes of the original participant/beneficiary per FDIC v. Bledsoe.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can Lincoln, as assignee, recover fees under ERISA §1132(g)(1)? | Lincoln stands in the shoes of the original participant/beneficiary. | Assignee status aligns with entitlement under §1132(g)(1). | Yes; Lincoln eligible for fees. |
| Must Bowen factors be applied to award fees under §1132(g)(1)? | Bowen factors must be applied. | Hardt allows discretion; factors not mandatory. | Not required; district court did not abuse discretion. |
Key Cases Cited
- Wade v. Hewlett-Packard Dev. Co. LP Short Term Disability Plan, 493 F.3d 533 (5th Cir. 2007) (ERISA fee awards and standards of review)
- Hardt v. Reliance Standard Life Ins. Co., 130 S. Ct. 2149 (Supreme Court 2010) (fee awards under §1132(g)(1) need some degree of success; five Bowen factors not required)
- FDIC v. Bledsoe, 989 F.2d 805 (5th Cir. 1993) (assignee stands in shoes of original beneficiary/participant)
- Iron Workers Local No. 272 v. Bowen, 624 F.2d 1255 (5th Cir. 1980) (fee award considerations not strictly controlling under ERISA)