This recent Eight Circuit case–Pendleton v. QuickTrip Corporation–is an ERISA 510 case that did not make it past a Motion for Summary Judgement. However, the case is noteworthy for the court’s discussion of attorneys’ fees:
The district court’s decision to deny attorney fees in this case was entered on the docket as ordered denied without authority. This statement could be interpreted as a determination that QuikTrip had not made a sufficient showing of factors in its favor to authorize an award of fees, but it is not free of ambiguity. Trial courts have many demands on their time, but nonetheless a district court should state the factors it is relying on in deciding an ERISA fee motion. See e.g. Toy v. Plumbers & Pipefitters Local Union No. 74 Pension Plan, 2009 WL 692398, *2 (3d Cir. 2009); Riley v. Admr of Supersaver 401K Capital Accumulation Plan for Employees of Participating AMR Corp. Subsidiaries, 209 F.3d 780, 782 (5th Cir. 2000).