Christopher Templin v. Independence Blue Cross
785 F.3d 861
3rd Cir.2015Background
- Appellants sought ERISA attorney’s fees after district court denied fees following a settlement on interest in 2013.
- Original ERISA denial-of-benefits suit (and two state-law claims) filed 2009; district court allowed benefits review, then paid claims and dismissed.
- Appellants and Appellees later sought fees/costs; district court denied fees.
- On remand, district court tentatively favored federal interest rate; settlement of $68,000 occurred, ending litigation on merits.
- Hardt v. Reliance Standard Life Ins. informs the “some degree of success” standard for ERISA fee awards.
- District court misapplied Ursic factors and required judicial action for catalyst theory; this appeal seeks reversal and remand for proper analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the catalyst theory available for ERISA fees post Buckhannon? | Appellants—catalyst theory applies | Appellees—Buckhannon limits catalyst theory | Catalyst theory available under ERISA. |
| Must some success on the merits require a judicial act to count? | Some success under Hardt does not require judicial action | Success must be tied to judicial action | No judicial action required to show some success. |
| Were Ursic factors misapplied in denying fees? | District Court erred by misapplying factors 1 and 5 | Factors considered appropriately | District court abused discretion; remand for correct Ursic analysis. |
Key Cases Cited
- Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242 (2010) (ERISA fee eligibility without a prevailing-party requirement; some success needed.)
- Buckhannon Board & Care Home v. West Virginia Dept. of Health & Human Services, 532 U.S. 598 (2001) (catalyst theory rejected for FHAA/ADA; affects pre-Buckhannon scope.)
- Ursic v. Bethlehem Mines Co., 719 F.2d 670 (3d Cir. 1983) (five-factor test for fee awards under Ursic.)
- Scarangella v. Group Health, Inc., 731 F.3d 146 (2d Cir. 2013) (catalyst theory applied post-Buckhannon to ERISA settlements.)
- Maher v. Gagne, 448 U.S. 911 (1980) (detailing some success standard for fee awards.)