Elizabeth Hammell, on behalf of herself and as executrix and trustee of the Estates of Herbert and Marcia Hebel, as well as on behalf of the Pilot Products, Inc. Defined Benefit Pension Plan v. Pilot Products, Inc. Defined Benefit Pension Plan; Pilot Products, Inc.; and Carolyn Hebel

District Court, E.D. New York·Decided July 15, 2026·No. 1:21-cv-00803·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ---------------------------------------------------------- X : ELIZABETH HAMMELL, on behalf of : herself and as executrix and trustee of the : MEMORANDUM DECISION AND Estates of Herbert and Marcia Hebel, as well : ORDER as on behalf of the Pilot Products, Inc. : Defined Benefit Pension Plan : 21-cv-0803 (BMC) : Plaintiff, : : - against - : : PILOT PRODUCTS, INC. DEFINED : BENEFIT PENSION PLAN; PILOT : PRODUCTS, INC.; and CAROLYN : HEBEL, : : Defendants. : : ---------------------------------------------------------- X

COGAN, District Judge.

Plaintiff Elizabeth Hammell moves under 29 U.S.C. § 1132(g)(1) to recover the attorneys’ fees and costs that she incurred while defending this Court’s judgment in her favor on appeal. See Hammell v. Pilot Prods., Inc. Defined Benefit Pension Plan, No. 24-3283-cv (Lead), 2026 WL 586699 (2d Cir. Mar. 3, 2026). She claims that a fee award of $368,978.20, an amount that she has voluntarily reduced by 15% from her actual time charges of $434,092 (consistent with the Court’s order awarding fees incurred through trial), is necessary to restore herself to the position that she would have been in but for defendant Carolyn Hebel’s fiduciary breach and litigation conduct. Additionally, she claims that she is entitled to recoup $7,233.16 in costs. For the reasons set forth below, the motion is granted in part. BACKGROUND In 2024, the Court held a bench trial in this Employee Retirement Income Security Act (“ERISA”) case and ruled largely in plaintiff’s favor. In a decision from the bench, the Court awarded her a $1,780,321.23 judgment on her duty of care claim, which was 92% of the

damages she sought for her four total claims. In 2025, the Court granted in part plaintiff’s motion for attorneys’ fees, costs, sanctions, and pre- and post-judgment interest, and entered an amended judgment that included the fees and costs. Hammell v. Pilot Prods., Inc. Defined Benefit Pension Plan, No. 21-cv-0803, 2025 WL 71705 (E.D.N.Y. Jan. 10, 2025) Defendants appealed the Court’s amended judgment, challenging only the judgment in favor of plaintiff on the duty of care claim and declining to challenge the fee award.1 Plaintiff subsequently cross-appealed the judgment in favor of defendants on the duty of loyalty claim. The Second Circuit affirmed this Court’s decision. Plaintiff now moves to collect attorneys’ fees and costs for her expenses incurred during the appeal, including those incurred in connection with pursuing her cross-appeal.

DISCUSSION ERISA provides that the Court “in its discretion may allow a reasonable attorney’s fee and costs of action to either party.” 29 U.S.C. § 1132(g)(1). “[I]n light of the ERISA fee provision’s statutory purpose of vindicating retirement rights, granting a prevailing plaintiff’s request for fees is appropriate absent some particular justification for not doing so.” Donachie v. Liberty Life Assur. Co. of Bos., 745 F.3d 41, 47 (2d Cir. 2014) (internal quotation marks and citations omitted). A court may award fees and costs under § 1132(g)(1) if the fee claimant has

1 See Hammell, 2026 WL 586699, at *1 n.2 (“Similarly, if her arguments on appeal are rejected regarding the claim for breach of the fiduciary duty of care, Carolyn does not separately challenge the district court’s award to Elizabeth of attorneys’ fees and costs, pursuant to 29 U.S.C. § 1132(g)(1).”). achieved “some degree of success on the merits.”2 Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242, 245 (2010) (quoting Ruckelshaus v. Sierra Club, 463 U.S. 680, 694 (1983)). Courts in this Circuit have awarded appellate fees in ERISA cases in which the plaintiff-appellees were successful at both the district and circuit levels. See, e.g., Buckley v. Slocum Dickson Med.

Grp., PLLC, 111 F. Supp. 3d 218 (N.D.N.Y. 2015); L.I. Head Start Child Dev. Servs., Inc. v. Econ. Opportunity Comm’n of Nassau Cty., Inc., No. 00-cv-7394, 2013 WL 6388633 (E.D.N.Y. Dec. 5, 2013). As the Second Circuit had no occasion to address the matter of appellate fees in its decision, this Court will decide that question. See L.I. Head Start Child Dev. Servs., 2013 WL 6388633, at *2 (“[N]othing in the Appellate Rules of Civil Procedure requires the Second Circuit’s judicial imprimatur before a district court may actually award such fees.”). The Court indicated during the trial phase that plaintiff was “overwhelmingly successful” in terms of damages recovered despite failing on three out of four claims. Hammell, 2025 WL 71705, at *1. Given that the Second Circuit fully affirmed this Court’s ruling, plaintiff should, once again, be

able to recover fees and costs, having satisfied the standard of attaining “some degree of success” at the proceedings in connection with the appeal. See Hardt, 560 U.S. at 245 (quoting Ruckelshaus, 463 U.S. 680 at 694). Defendants argue that plaintiff has already been made whole through the underlying judgment and trial-phase fee award, and so an appellate fee award would constitute an additional windfall. This argument doesn’t make much sense. It was defendants who chose to appeal.

2 Plaintiff’s motion discusses the five-factor test from Chambless v. Masters, Mates & Pilots Pension Plan, 815 F.2d 869, 871 (2d Cir. 1987). Hardt narrowed the precedential value of this decision, stating that “[b]ecause these five factors bear no obvious relation to § 1132(g)(1)’s text or to our fee-shifting jurisprudence, they are not required for channeling a court’s discretion when awarding fees under this section.” 560 U.S. at 254-55. That was their right, but if they hadn’t exercised it, plaintiff wouldn’t have incurred any further fees to defend the underlying judgment in her favor. Doing so reduced her total recovery and thus diminished the extent to which she was made whole. Defendants also argue that plaintiff should not be compensated for fees incurred in

pursuing her cross-appeal. The Court disagrees. Plaintiff brought her cross-appeal as an alternative ground for affirmance in the event that defendants prevailed on their appeal, making plaintiff’s cross-appeal one component of an overall successful action – a reasonable step to “preserve and protect the judgment” in her favor – rather than a separate, unsuccessful procedure. Plainly put, the appeal and cross-appeal were inextricably intertwined; plaintiff’s cross-appeal would not have even existed but for defendants’ appeal. Even though, in the end, plaintiff did not gain anything by pursuing the cross-appeal, it was a reasonable step to take in the pursuit of affirming the judgment attained at trial. The parties’ present dispute over appellate fees echoes the parties’ prior dispute over trial-phase fees. After plaintiff’s substantial victory on one of her four claims, defendants sought

to cabin plaintiff’s fees to just that successful claim. The Court rejected this attempt, holding that plaintiff’s three unsuccessful claims “share[d] ‘a common core of facts’” with her successful claim and awarding plaintiff attorneys’ fees for all her claims. See Hammell, 2025 WL 71705, at *1 (quoting Reed v. A.W.

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Elizabeth Hammell, on behalf of herself and as executrix and trustee of the Estates of Herbert and Marcia Hebel, as well as on behalf of the Pilot Products, Inc. Defined Benefit Pension Plan v. Pilot Products, Inc. Defined Benefit Pension Plan; Pilot Products, Inc.; and Carolyn Hebel, (E.D.N.Y. 2026).

Elizabeth Hammell, on behalf of herself and as executrix and trustee of the Estates of Herbert and Marcia Hebel, as well as on behalf of the Pilot Products, Inc. Defined Benefit Pension Plan v. Pilot Products, Inc. Defined Benefit Pension Plan; Pilot Products, Inc.; and Carolyn Hebel (Elizabeth Hammell, on behalf of herself and as executrix and trustee of the Estates of Herbert and Marcia Hebel, as well as on behalf of the Pilot Products, Inc. Defined Benefit Pension Plan v. Pilot Products, Inc. Defined Benefit Pension Plan; Pilot Products, Inc.; and Carolyn Hebel) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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