Thomas R. v. Hartford Life and Accident Insurance Company

Background

Thomas R. and his guardian, Gino F., sued Hartford Life and Accident Insurance Company (Hartford) to recover benefits allegedly due under Tara R.’s life-insurance plans. The plans were employee welfare benefit plans governed by the Employee Retirement Income Security Act (ERISA). Tara R. was Thomas R.’s mother, and Thomas R. was the beneficiary listed on both plans.

The parties disputed whether coverage had begun before Tara R.’s death. The court previously denied both sides’ motions for summary judgment because it found that relevant contractual terms were ambiguous and that factual issues remained. After oral argument, the parties reported that they had settled the benefits dispute on November 6, 2024. The claim for attorney’s fees and costs remained unresolved.

Entitlement to Fees

Under ERISA, a court may award reasonable attorney’s fees and costs to either party. The court explained that an ERISA plaintiff must obtain “some degree of success on the merits” to receive fees. Hartford conceded at oral argument that the plaintiffs had achieved some degree of success. The court held that this concession was sufficient to support a fee award and that it did not need to analyze the additional factors sometimes considered in ERISA fee decisions. Hartford identified no particular justification for denying fees.

Amount of Fees

The plaintiffs’ attorneys requested compensation based on hourly rates ranging from $300 to $925 and a total of approximately 451 hours. The opinion reports two slightly different figures for the requested attorney’s-fee amount: $245,134.12 in the initial description of the motion and $245,143.12 in the later discussion. The later discussion states that the request reflected a voluntary 10% reduction from $272,371.25 in calculated fees.

Hartford argued that the fee award should not exceed the $125,000 value of the life-insurance benefits. The court rejected a per se rule limiting an ERISA fee award to the amount of benefits sought or recovered. It also found that the requested hourly rates were high compared with some recent awards in the district, although evidence supported the firm’s rates. The court reduced the requested hourly rates by 10%.

The court also found that some billed hours were excessive in light of the relatively small administrative record and the case’s contract-interpretation issues. It cited, among other examples, more than 20 hours for an eight-page complaint and initial litigation documents, more than 50 hours for settlement-related work, and nearly 130 hours for responses to the defendant’s trial submissions. The court applied a further 20% reduction to the billed hours.

Disposition

The court awarded the plaintiffs $194,756.58 in reasonable attorney’s fees. It also granted the plaintiffs’ request for $518.44 in costs for filing, service, transcripts, and courtesy copies. Because the parties had settled the benefits dispute, the court directed the Clerk to enter judgment for the plaintiffs and against Hartford for those amounts, close all pending motions, and close the case.