In its analysis, the Court applied the five factor test set forth in Eddy v. Colonial Life Ins. Co., 59 F.3d 201, 206 (D.C. Cir. 1995): (1) the losing party's culpability or bad faith; (2) the losing party's ability to satisfy a fee award; (3) the deterrent effect of such an award; (4) the value of the victory to plan participants and beneficiaries, and the significance of the legal issue involved; and (5) the relative merits of the parties' positions.

As to the first factor, the Court found that while LINA may have been justified in its initial denial of Plaintiff's claim because of the lack of conclusive information about her condition, its delay of Plaintiff's appeal due to its purported need for expert review of the claim suggested bad faith. There was no evidence that LINA's medical consultant evaluated Plaintiff's claim file other than a short notation (made by someone else) reflecting his finding. LINA's delay in the review of Plaintiff's appeal, coupled with the review by its medical consultant, weighed in favor of a finding of bad faith. Moreover, the Court found that LINA missed the deadline for issuing its decision on appeal.

As to the second factor, LINA did not contest that it had the ability to satisfy an award of attorneys' fees; therefore, this factor also weighed in favor of the Plaintiff. The Court further found that the deterrence factor weighed in favor of the Plaintiff because awarding attorneys' fees provides added incentive to comply with ERISA. The Court found that the fourth factor weighed equally in favor of both the Plaintiff and the Defendant. Finally, as to the fifth factor, the Court concluded that by the time Finks submitted her appeal and all supporting documentation, the cumulative medical evidence favored a finding of disability. Thus, the Court found that the "relative merit" factor weighed in favor of the Plaintiff. Because the Court found that the majority of the Eddy factors favored the Plaintiff, it awarded attorneys' fees relating to the litigation of her claim.

However, the Court acknowledged that the D.C. Circuit had not addressed the issue of whether fees incurred during an ERISA administrative review were recoverable. ERISA provides that "[i]n any action under this title . . . by a participant, beneficiary, or fiduciary, the court in its discretion may allow a reasonable attorney's fee and costs of action to either party." 29 U.S.C. § 1132(g)(1). The Court looked to the seven circuits that have addressed this issue, all of which determined that awarding pre-litigation fees is not appropriate. Accordingly, the Court held that the Plaintiff was not allowed to recover legal fees incurred during administrative proceedings.