Winning the merits of an ERISA long-term disability lawsuit may not resolve every financial issue. In Boothe v. First Reliance Standard Life Insurance Co., a claimant had received long-term disability benefits after injuries prevented her from performing her nursing occupation. The insurer later terminated the benefits. She completed an internal appeal, filed suit, and won summary judgment in March 2026.
The October 13, 2026 decision addressed the next stage: attorney’s fees, litigation costs, and interest on benefits that had been withheld. The document is a report and recommendation from a federal magistrate judge, so the district judge may accept, reject, or modify it.
What the magistrate judge recommended
The magistrate judge recommended $145,775 in attorney’s fees and $2,905 in costs. The fee calculation used a $700 hourly rate and 208.25 hours. That was less than counsel requested because the court found the proposed $805 rate higher than warranted by comparable Southern District cases and reduced the claimed hours by 15 percent.
The hours reduction focused on block billing, vague descriptions, and clerical tasks billed at an attorney’s rate. The report also recommended prejudgment interest at the federal rate under 28 U.S.C. § 1961 rather than New York’s nine-percent statutory rate. On the record presented, the magistrate judge concluded that the federal rate would compensate for delayed payment without overcompensation.
A merits win can lead to separate remedies questions
The recommendation illustrates the difference between winning benefits and resolving the consequences of delayed payment. The claimant’s summary-judgment victory supplied the required degree of success on the merits for fee eligibility. It did not automatically determine the fee amount, allowable costs, or interest rate. Each question required its own proof and legal analysis.
For claimants, the practical lesson is to preserve the termination notice, internal appeal, plan documents, benefit calculations, and payment history. Those materials can matter when counsel evaluates both the benefits dispute and possible relief after a court ruling. Counsel’s own detailed, contemporaneous billing records also matter when a fee request is later reviewed.
The limits of the decision
Boothe does not establish that every successful ERISA claimant will recover all requested fees or receive a particular interest rate. ERISA gives courts discretion over reasonable fees and costs, and prejudgment interest depends on the governing law and the record. This unpublished district-court recommendation is not binding precedent, and it is not itself an order adopting the recommended amounts.
Feden Law Group can help assess an ERISA disability denial, administrative appeal, or federal court issue. Learn about our disability practice or schedule an initial consultation.
You can also explore the FLG Claim Analyst (Beta).
This article provides general information, not legal advice. Reading it or requesting a consultation does not create an attorney-client relationship.