Breakdown of the Ask
In addition to the $23 million legal fee, the motion seeks:
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$735,000 in litigation cost reimbursements
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A $50,000 service award for Kim Snyder, the former UnitedHealth employee who initiated the lawsuit in April 2021
The service award, the lawyers argue, is justified by Snyder’s 340 hours of personal time invested over four years. To sweeten the optics, half of that award will come from the attorneys’ own reimbursements to protect the class’s financial recovery.
The Allegations: Loyalty or Lucrative Ties?
Snyder’s lawsuit alleged UnitedHealth refused to ditch underperforming Wells Fargo investment funds in its 401(k) plan to preserve a lucrative business relationship with the bank. According to her complaint, the funds trailed behind 70–90% of peer funds over a decade, costing employees hundreds of millions in lost gains.
The claims struck at the core of fiduciary responsibility under the Employee Retirement Income Security Act (ERISA), accusing UnitedHealth of putting corporate partnerships ahead of employee retirement security.
