ERISA "denied benefits" remand "attorney's fee" "Hardt v. Reliance Standard Life Insurance" "Gelumbaukskas v. USG Corporation Retirement Plan Pension and Investment Committee"

I posted recently on the Supreme Court’s consideration in Hardt v. Reliance Standard Life Insurance of the question of just how much success on the merits is necessary to trigger a plan participant’s right to an award of attorneys’ fees, and discussed the fact that requiring an outright and complete win by the plan participant