2009 Supreme Court term

BRIDGET HARDT v. RELIANCE STANDARD LIFE INSURANCE COMPANY.

Dockets 09-448Argued
AI-generated independent summary

This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.

In brief

Overview

According to Petitioner, petitioner Bridget Hardt seeks attorney’s fees under ERISA §502(g)(1) after a procedural victory.

The case raises the question of whether a party who achieves only a procedural success, without final relief, is eligible for fee awards.

Background and question before the Court

According to Petitioner, the Fourth Circuit vacated an award of attorney’s fees to Hardt even though the district court found the insurer violated ERISA in bad faith and ordered a redetermination of benefits within 30 days; Hardt subsequently secured full disability benefits.

The central legal question is whether a party who wins only a procedural victory may be awarded attorney’s fees under ERISA.

What each side argues

Petitioner Position

Petitioner argues she is entitled to an attorney’s fee award under ERISA §502(g)(1) by applying the Court’s established fee standards.

What happened at oral argument

Justice Sotomayor asked: “How could somebody have some success on the merits if they don't achieve a judgment of some sort?”

According to Justice Scalia, justice Scalia questioned whether fees are assessable when the only victory is procedural.

Justice Breyer asked whether a party who wins only a technical hearing should receive attorney’s fees.

According to Chief Justice Roberts, chief Justice Roberts wondered about a scenario where a plaintiff wins every procedural issue but ultimately loses on the merits.

Justice Stevens asked whether treating the statute as having a prevailing‑party clause is appropriate.

According to Justice Breyer, justice Breyer later questioned the discretion of district judges to award fees when the plaintiff obtains some benefit.

According to Justice Ginsburg, justice Ginsburg posed a hypothetical about entitlement to documents in an interlocutory order.

Justice Sotomayor asked what distinguishes a prevailing party from a mere success on the merits.

What the Court decided

Pending This section will be added when the relevant Court material is available.

Why it matters

Source-limited The available primary sources do not support a complete explanation yet.

Terms to know

No glossary terms are available for this guide.

Primary sources

Read the source materials on the official site or open the immutable repository copy used for this guide.

  • f770e1d7ada5565d9816-r1-dcda670d3683c788.pdforal argument transcript

Guide generated September 23, 2026. Automated validation accepted this version.