Case Story: Our Client v. Metropolitan Life Insurance Company
After arguing the substantive issues of this case in the United States District Court for the Eastern District of Tennessee, the District Court remanded this case to MetLife for a proper decision. Magistrate Judge Carter had filed a report and recommendation with the district court. Id. The District Court accepted and adopted that report, awarding us $16,933 in attorney’s fees, including $350 as reimbursement for the client’s original court-filing fee. Id.
The District Court discussed when an award of attorney’s fees is appropriate and how to calculate the amount awarded. Id. Under the law then in effect in the Sixth Circuit, an award of attorney fees in an ERISA case is appropriate when five factors are considered, including the relative merits of the parties’ positions. Id. (citing Schwartz v. Gregori, 160 F.3d 1116, 1119 (6th Cir. 1998); Secretary of Dep’t of Labor v. King, 775 F.2d 666, 670 (6th Cir. 1985)). Also, attorney’s fees are appropriate when the requesting party provides documentation which proves that he or she is entitled to the requested amount. Id. at *5 (citing Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); Reed v. Rhodes, 179 F.3d 453, 472 (6th Cir. 1999)). The district court generally has discretion to award attorney’s fees. Id.
Further, under the federal fee shifting statutes, successful parties can claim attorney’s fees using the “lodestar” method to calculate the appropriate amount of fees. Id. at *5 (citing Web v. Board of Educ. Of Dyer County, Tenn, 471 U.S. 234, 242 (1985); Hensley, 461 U.S. at 433; Adcock-Ladd v. Secretary of the Treasurer, 227 F.3d 343, 349 (6th Cir. 2000); Reed, 179 F.3d at 471). The “lodestar” method multiplies the number of hours reasonably expended by a reasonable hourly rate. Id. The appropriate hourly rate should be the prevailing market rate in the legal community within the court’s territorial jurisdiction for the same type of case. Id. at *5 (citing Adcock-Ladd, 227 F.3d at 350). To determine whether the hours expended are reasonable, courts should consider the difficulty of the legal issues in the case, the skill required to properly provide legal services, and the experience and ability of the attorneys. Id. at *6 (citing Hensley, 461 U.S. at 430 n. 3). Additionally, and most important, courts should consider the degree of success obtained by the fee-requesting party. Id. (quoting Farrar v. Hobby, 506 U.S. 103, 114 (1992)(citing Hensley, 461 U.S. at 436); Cramblit v. Fiske, 33 F.3d 633, 635 (6th Cir. 1994).
The district court found that we had set forth in detail the hours spent working on this claim by attorneys and paralegals and that the hours and rates were reasonable in light of the work done and the experience and expertise of the attorneys. Id. at *7.
