Mealey's (January 5, 2023, 11:46 AM EST) -- SAN FRANCISCO — Upholding denial of a disability claimant’s motion for attorney fees without deciding whether a catalyst theory of recovery applies in Employee Retirement Income Security Act cases, a Ninth Circuit U.S. Court of Appeals panel said in an unpublished memorandum disposition that there was no abuse of discretion in denying the fees based on the factors outlined in Hummell v. S. E. Rykoff & Co....