Jeffrey Lemons v. Reliance Standard Life Ins Co, 534 F. App'x 162

Lemons was employed by Amerisafe, Inc. (1999–Jan 15, 2001) and participated in the Amerisafe Plan, ERISA-governed; Reliance is the claim fiduciary and Plan insurer.
Lemons became disabled Jan 1, 2001 and applied for long-term disability benefits, which Reliance initially approved and later terminated (effective July 2, 2001).
Lemons’ SSDI began June 2002 per SSA notice in May 2003.
In 2005 Lemons sued Amerisafe, Reliance, and the Plan for arbitrary termination of benefits; in Feb 2006 Reliance reinstated benefits and offered to dismiss the suit but would not pay fees.
May 2006 Reliance informed Lemons of reinstatement and retroactive payment totaling $66,443.89 for July 2, 2001–May 2, 2006, offset by SSDI; payments began May 2006.
In 2011 the District Court denied summary judgment and held the case moot; Lemons sought reconsideration and attempt to pursue attorney’s fees under Ursic analysis, which the court denied; on appeal the district court’s mootness ruling was affirmed, and Ursic-based fees remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the case moot after reinstatement of benefits?	Lemons argues mootness is not complete since amounts were miscalculated.	Defendants contend reinstatement resolves the dispute and monetary offset is a separate claim.	Yes, moot; reinstatement resolves the core dispute.
Whether Lemons may pursue attorney’s fees and which test applies (Ursic multi-factor vs prevailing party)	Lemons contends Ursic applies and he should be allowed to file for fees.	Defendants argue no fees under Ursic and that the case is moot, making fee motion inappropriate.	Remanded for full Ursic analysis; fee motion to be considered on remand.

Silk v. Metro. Life Ins. Co., 310 F. App’x 138 (9th Cir. 2009) (mootness when benefits reinstated can dispose of ERISA dispute)
Ursic v. Bethlehem Mines, 719 F.2d 670 (3d Cir. 1983) (multifactor Ursic test for fees in ERISA actions)