Mealey's (July 26, 2018, 11:57 AM EDT) -- SACRAMENTO, Calif. — A disability claimant is not entitled to attorney fees and costs because she did not achieve success in an “action” under the Employee Retirement Income Security Act’s attorney fee provision, a California federal judge said July 23, noting that the court did not rule on any substantive motions of the merits in the suit (Brenda Culbertson-Chavira v. Life Insurance Company of North America, No. 17-1702, E.D. Calif., 2018 U.S. Dist. LEXIS 122872)....