Steven Spain v. Aetna Life Insurance Company Trans World Airlines Employees Benefits Plan

OVERVIEW

Steven Spain (“Spain”) appeals the district court’s denial of his motion for attorneys’ fees in his suit against Aetna Life Insurance (“Aetna”), the administrator of his employee benefit plan. The district court denied Appellant’s motion for attorneys’ fees' on the grounds that attorneys’ fees could not be awarded against a plan administrator in an action for plan benefits. We reverse the judgment and remand for a determination of whether any award of fees is appropriate. This court has jurisdiction under 28 U.S.C. § 1291 .

FACTUAL AND PROCEDURAL BACKGROUND

Spain, an employee of Trans World Airlines (“TWA”), was covered under Trans World Airlines’s employee benefit plan (“Plan”), a self-funded employee welfare benefit plan within the meaning of the Employee Retirement Income Security Act of 1974 (“ERISA”). See 29 U.S.C, § 1002(1) (1988). This Plan was administered by Aetna.

In January 1990, Spain was diagnosed with testicular cancer. His doctors decided that an autologous bone marrow transplant was necessary. This treatment has three main steps. First, some of the patient’s bone marrow is removed. Second, the patient undergoes chemotherapy to destroy the body’s…