L. v. UNUM Life Insurance Company of America

Background

After a bench trial—a trial decided by a judge rather than a jury under Federal Rule of Civil Procedure 52—the court entered judgment for Jessica L. The court had concluded that retroactive reinstatement of benefits through the date of judgment was proper. The parties had not addressed how much those retroactive benefits should be, so the court did not calculate that amount or include it in the judgment.

Jessica L. then moved to amend the judgment to add an amount for retroactive benefits and moved for attorneys’ fees. After briefing ended, UNUM reported that it had paid approximately $203,000 in retroactive benefits, plus interest. The court stated that approximately $43,000, not including interest, appeared to remain disputed. The court could not determine from the record how much, if any, additional amount was owed, and it was not clear whether the parties had adequately discussed the issue with each other.

Motion to Amend Judgment

The court did not rule on the amount of retroactive benefits. Instead, it ordered the parties to meet and confer in person or by video by October 17, 2025. If they could not resolve the dispute, they were ordered to file a joint submission by November 7, 2025, explaining their positions, including a chart of each disputed figure with appropriate record citations and the relevant insurance-plan provisions. If they reached an agreement, they were to submit a stipulated proposed amended judgment by that date.

The court declined to remand the dispute for the reasons stated in its prior order. The opinion does not state a final disposition granting or denying the motion to amend judgment.

Attorneys’ Fees and Expenses

Jessica L. requested approximately $346,000 in attorneys’ fees, approximately $7,500 in litigation expenses, and prejudgment interest at 4.09%. UNUM primarily argued that the attorneys’ rates and hours were excessive. The court rejected that objection, finding that the submitted evidence supported market-based rates and that the billing records did not show excessive time. The court noted the voluminous record, the complex medical history, counsel’s successful result, and counsel’s representation that it had omitted inefficient or duplicative work from its billing. The court’s own review also found the billed hours reasonable.

UNUM challenged expenses for meals, commuting, and legal research. The court found that Jessica L. had submitted evidence that these costs were generally charged to clients and were commonly charged by similar firms, including in the district. The court also noted that the parties appeared to agree on the application of prejudgment interest and that UNUM had already paid more than $10,000 in prejudgment interest at a rate of 4.09%.

Ruling

Judge Rita F. Lin granted the motion for attorneys’ fees. The court ordered UNUM to pay Jessica L. $346,685 in attorneys’ fees and $7,536.22 in litigation expenses. It also ordered UNUM to pay prejudgment interest at 4.09% on future payments of retroactive benefits, measured from the same day used to calculate the prejudgment interest already paid. The parties may file additional attorneys’ fees briefing as needed for work connected to the meet-and-confer process and the further submission concerning the motion to amend judgment.