Federal 7th Circuit Court
Civil Court
Mootness Doctrine
In ERISA action seeking long-term disability benefits and attorney fees, Dist. Ct. erred in denying defendant-plan's motion to dismiss where defendant had previously informed plaintiff that it would (and did pay) benefits requested in instant case plus interest. Plaintiff's receipt of her requested benefits and interest rendered case moot and served to deprive Dist. Ct. of jurisdiction to enter subsequent order granting plaintiff's motion for summary judgment. Dist. Ct. did not err in denying plaintiff's motion for attorney fees where fee petition had failed to contain any documentation to support assertion of reasonable hourly rate or amount of time spent on case. Fact that defendant did not challenge amount of time asserted by plaintiff's counsel did not require different result.