Welch filed suit challenging MetLife’s denial of long-term disability benefits. Approximately six months after litigation began, MetLife paid the claim in full, converting the case into a dispute over attorney’s fees incurred to obtain payment.
The district court substantially reduced the fee award, lowering hourly rates and imposing across-the-board reductions based on billing practices.
The Ninth Circuit held that portions of the reduction were improper, rejected artificially low hourly rates, and remanded for recalculation. The decision affected how attorney’s fees are evaluated when insurers pay valid claims only after litigation forces the issue.
