Rhodes v. First Reliance Standard Life Insurance Company
- Alvin Hellerstein
- 1:22-cv-05264
- U.S. District Court · Southern District of New York
- 2
In Rhodes v. First Reliance, Judge Hellerstein found $121,999.28 in attorneys’ fees reasonable but denied $917.65 in medical-file costs.
William Rhodes and First Reliance Standard Life Insurance Company; the ruling addressed Rhodes’s request for attorneys’ fees and costs.
What happened
In Rhodes v. First Reliance Standard Life Insurance Company, the court considered William Rhodes’s request for attorneys’ fees and costs after finding that First Reliance violated the Employee Retirement Income Security Act’s claim-procedure rules and denied Rhodes a full and fair review of his claims.
The court found Rhodes’s request for $121,999.28 in attorneys’ fees reasonable. It said the amount reflected the work completed, included a 10% reduction for possible inefficiencies, and used reasonable rates. The court denied Rhodes’s request for $917.65 in medical-file costs because it considered that expense part of the legal work-up rather than a recoverable cost.
Judge Alvin K. Hellerstein found the attorneys’ fee request reasonable and denied the medical-file cost request.
The detailed version
- Rhodes v. First Reliance Standard Life Insurance Company · No. 1:22-cv-05264
- Alvin Hellerstein
- Dec. 27, 2023
Background
The court previously held that First Reliance Standard Life Insurance Company violated claim-procedure regulations under the Employee Retirement Income Security Act (ERISA). The violation denied William Rhodes a full and fair review of his claims. The remaining issue was the amount of reasonable attorneys’ fees and costs.
Attorneys’ Fees
The court found Rhodes’s request for $121,999.28 in attorneys’ fees reasonable. The court stated that the request reflected the work performed in the case and included a 10% reduction that adequately accounted for possible inefficiencies. It also found that the rates charged by Riemer Hess were reasonable in light of the firm’s experience and capability in similar matters.
Costs
The court denied Rhodes’s request for $917.65 spent keeping his medical file current. It concluded that this expense was better classified as part of the legal work-up and was not recoverable as a litigation cost.
Ruling
Judge Alvin K. Hellerstein found the request for $121,999.28 in attorneys’ fees reasonable and denied the request for $917.65 in medical-file costs.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.