Abrams v. Unum Life Insurance Company of America

CourtDistrict Court, W.D. Washington
DecidedFebruary 27, 2023
Docket2:21-cv-00980
StatusUnknown

This text of Abrams v. Unum Life Insurance Company of America (Abrams v. Unum Life Insurance Company of America) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Abrams v. Unum Life Insurance Company of America, (W.D. Wash. 2023).

Opinion

1 2

3 4 5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 WILLIAM F. ABRAMS, 8 Plaintiff, 9 v. C21-0980 TSZ 10 UNUM LIFE INSURANCE ORDER COMPANY OF AMERICA, 11 Defendant. 12

13 THIS MATTER comes before the Court on Plaintiff’s motion for attorneys’ fees 14 and costs, docket no. 45. Having reviewed all papers filed in support of, and in opposition 15 to, the motion, the Court enters the following order. 16 Background 17 The Court has detailed the background of this case in a previous Order. Docket 18 no. 43. Plaintiff brought this action under the Employee Retirement Income Security Act 19 (“ERISA”), specifically 29 U.S.C. § 1132(a)(1)(B). The Court granted Plaintiff’s motion 20 under Federal Rule of Civil Procedure 52(a). Plaintiff seeks attorneys’ fees and costs 21 22 1 under 29 U.S.C. § 1132(g)(1). Plaintiff requests attorneys’ fees of $243,958 based on 2 341.2 hours at a rate of $715 per hour. Plaintiff also claims costs of $2,353.75.1

3 Discussion 4 In an ERISA action, the court has discretion to award reasonable attorneys’ fees 5 and costs to either party if the party seeking fees has achieved “some degree of success 6 on the merits.” Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242, 255 (2010) 7 (quoting Ruckelshaus v. Sierra Club, 463 U.S. 680, 694 (1983)). Plaintiff has achieved 8 considerable success on the merits. See docket no. 43.

9 A. The Hummell Factors 10 Once a court concludes that the claimant has satisfied the standard of success set 11 forth in Hardt, it must then consider the five factors outlined by the Ninth Circuit in 12 Hummell v. S.E. Rykoff & Co., 634 F.2d 446 (9th Cir. 1980); see also Simonia v. 13 Glendale Nissan/Infiniti Disability Plan, 608 F.3d 1118, 1119 (9th Cir. 2010). Those

14 factors are, 15 (1) the degree of the opposing parties’ culpability or bad faith; (2) the ability of the opposing parties to satisfy an award of fees; (3) whether an award of 16 fees against the opposing parties would deter others from acting under similar circumstances; (4) whether the parties requesting fees sought to benefit all 17 participants and beneficiaries of an ERISA plan or to resolve a significant legal question regarding ERISA; and (5) the relative merits of the parties’ 18 positions.

19 Hummell, 634 F.2d at 453. When the court applies these factors, it “must keep at the 20 forefront ERISA’s remedial purposes that should be liberally construed in favor of 21 22 1 Defendant does not contest the reasonableness of Plaintiff’s costs. 1 protecting participants in employee benefit plans.” McElwaine v. U.S. West, Inc., 176 2 F.3d 1167, 1172 (9th Cir. 1999). “[A] successful ERISA participant should ordinarily

3 recover an attorney’s fee unless special circumstances would render such an award 4 unjust.” Id. 5 Plaintiff argues that he is entitled to fees and costs because (1) Defendant is able to 6 satisfy a fee award; (2) an award of fees will deter Defendant from failing to 7 communicate important information to participants when managing their claims; (3) a fee 8 award to Plaintiff would prompt Defendant to manage disability claims with more care,

9 benefiting other participants; and (4) Plaintiff’s position is relatively more meritorious. 10 See Mot. (docket no. 45). Defendant argues that fees are unwarranted because (1) 11 Defendant did not act in bad faith; (2) although Defendant is able to pay, this fact is not 12 enough to force Defendant to bear this burden; (3) there is no need for deterrence here 13 because Defendant did not act in bad faith; (4) a fee award does not benefit all

14 participants or beneficiaries of the plan; and (5) the relative merits of the parties’ 15 positions do not support a full fee award. 16 The Hummell factors do not require the Court to find that each factor weighs in 17 support of fees because the factors “reflect a balancing.” McElwaine v. US W., Inc., 176 18 F.3d 1167, 1173 (9th Cir. 1999). As an initial matter, the Court did not find that

19 Defendant’s actions rise to level of bad faith or culpability required under the first 20 Hummell factor, docket no. 43, so the first factor weighs against a fee award. 21 Second, Defendant is able to satisfy the fee award. Defendant concedes this point. 22 Therefore, this factor weighs in favor of a fee award. Third, although Defendant did not 1 act in bad faith, an award of fees could deter other plan administrators from denying 2 coverage based on a lack of a unifying diagnosis, rather than focusing on the question of

3 whether the plaintiff is sick. Defendant argues that this factor should not weigh in favor 4 of an award because in the absence of factor one—culpability or bad faith—“there is no 5 need to make an example of a party in order to deter others.” Providence Health Sys.– 6 Wash. v. Bush, No. C06-5268, 2007 WL 505657, at *2 (W.D. Wash. Feb. 12, 2007). The 7 Ninth Circuit has found, however, that even in the absence of bad faith or culpability, that 8 the deterrence factor can weigh in favor of a fee award. McElwaine, 176 F.3d at 1173.

9 The Court declines to adopt Defendant’s reading of the third Hummell factor because that 10 reading would render the third factor a nullity. Fourth, there is no evidence that Plaintiff 11 sought to benefit all plan participants. Therefore, the fourth Hummell factor is neutral. 12 Fifth, although Plaintiff did succeed on the merits, the thin margin by which 13 Plaintiff succeeded in this case warrants closer scrutiny. Because Plaintiff only carried his

14 burden by a small margin, and because Defendant did not act in bad faith, the principles 15 of equity counsel in favor of reducing any fee award by a 10% “haircut.” Moreno v. City 16 of Sacramento, 534 F.3d 1106, 1112 (9th Cir. 2008) (“[T]he district court can impose a 17 small reduction, no greater than 10 percent—a ‘haircut’—based on its exercise of 18 discretion and without a more specific explanation.”); cf. Great Hill Equity Partners IV,

19 LP v. SIG Growth Equity Fund I, LLLP, No. CV 7906, 2020 WL 7861336, at *7 (Del. 20 Ch. Dec. 31, 2020), aff’d sub nom. Herzog v. Great Hill Equity Partners IV, LP, 269 21 A.3d 983 (Del. 2021) (refusing to shift fees in equity when each party prevailed on 22 certain issues). 1 In sum, the Court concludes that the Hummell factors weigh in favor of awarding 2 Plaintiff reasonable attorneys’ fees and costs pursuant to 29 U.S.C. § 1132(g)(1), with a

3 reduction in the fee award as described above. 4 B. Reasonable Attorneys’ Fees 5 In determining the reasonable amount of fees and costs to award, courts use a 6 hybrid lodestar/multiplier approach. McElwaine, 176 F.3d at 1173. The Court arrives at 7 the “lodestar” figure by multiplying the number of hours reasonably expended by a 8 reasonable hourly rate. See id. Additionally, “[t]he party seeking fees bears the burden of

9 documenting the hours expended in the litigation and must submit evidence supporting 10 those hours and the rates claimed.” Welch v. Metro. Life Ins. Co., 480 F.3d 942, 945–46 11 (9th Cir.

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Ruckelshaus v. Sierra Club
463 U.S. 680 (Supreme Court, 1983)
Simonia v. Glendale Nissan/Infiniti Disability Plan
608 F.3d 1118 (Ninth Circuit, 2010)
Welch v. Metropolitan Life Ins. Co.
480 F.3d 942 (Ninth Circuit, 2007)
Moreno v. City of Sacramento
534 F.3d 1106 (Ninth Circuit, 2008)
718 ASSOCIATES v. Banks
21 A.3d 977 (District of Columbia Court of Appeals, 2011)
Hardt v. Reliance Standard Life Insurance Co.
176 L. Ed. 2d 998 (Supreme Court, 2010)
Bunger v. Unum Life Insurance Co. of America
231 F. Supp. 3d 865 (W.D. Washington, 2017)
Hummell v. S. E. Rykoff & Co.
634 F.2d 446 (Ninth Circuit, 1980)
United Steelworkers v. Phelps Dodge Corp.
896 F.2d 403 (Ninth Circuit, 1990)

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Abrams v. Unum Life Insurance Company of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abrams-v-unum-life-insurance-company-of-america-wawd-2023.