Third Circuit Endorses Catalyst Theory for Recovering ERISA Attorney's Fees | Practical Law
In Templin v. Independence Blue Cross, the US Court of Appeals for the Third Circuit held that the catalyst theory of recovery is available under the Employee Retirement Income Security Act of 1974 (ERISA). In addition to holding that a district court used the wrong legal standard in evaluating fee claimants' eligibility for ERISA attorney's fees, the Third Circuit concluded that the district court misapplied factors used by courts in deciding whether to grant or deny fees.