Bayer v. Commissioner of Social Security

CourtDistrict Court, W.D. New York
DecidedDecember 20, 2024
Docket1:19-cv-00009
StatusUnknown

This text of Bayer v. Commissioner of Social Security (Bayer v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bayer v. Commissioner of Social Security, (W.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK _______________________________________

BETHANY B.,1 DECISION & ORDER Plaintiff, 19-CV-0009MWP v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant. _______________________________________

PRELIMINARY STATEMENT On January 1, 2019, plaintiff Melissa W. (“plaintiff”) commenced this action seeking judicial review of a final decision of the Commissioner of Social Security (the “Commissioner”) denying her application for Disability Insurance Benefits and Supplemental Security Income (“DIB/SSI”). (Docket # 1). Pursuant to the Standing Order of the United States District Court for the Western District of New York regarding Social Security cases dated June 29, 2018, this case has been reassigned to, and the parties have consented to the disposition of this case by, the undersigned. (Docket # 14). On June 29, 2020, this Court entered a judgment reversing the Commissioner’s denial of DIB/SSI and remanding the case to the Commissioner pursuant to 42 U.S.C. § 405(g), sentence four, for further administrative proceedings. (Docket # 16). On September 28, 2020, the parties stipulated that the Commissioner would pay $5,799.86

1 Pursuant to the November 18, 2020 Standing Order of the United States District Court for the Western District of New York regarding identification of non-governmental parties in social security opinions, the plaintiff in this matter will be identified and referenced solely by first name and last initial. in attorneys’ fees in full satisfaction of plaintiff’s claim pursuant to the Equal Access to Justice Act (“EAJA”), 28 U.S.C. § 2412(d). (Docket # 20). After remand, plaintiff obtained a fully favorable decision on August 5, 2022 (Docket # 21-7), and received $ 101,423.00 in past-due benefits (Docket # 21-3 at 2). The

Commissioner withheld 25% of that award, or $ 25,355.75, to pay plaintiff’s counsel, the Law Offices of Kenneth R. Hiller PLLC (“Hiller”). (Docket ## 21-3; 21-4; 24 at 4). Hiller now moves, pursuant to 42 U.S.C. § 406(b) and its fee agreement with plaintiff (Docket ## 21, 21-5) (the “Agreement”), for an award of $ 25,355.75 in attorneys’ fees, which is 25% of plaintiff’s award. (Docket # 21-1 at 2). The Commissioner responded to the motion acknowledging that the fee application appeared timely and that there did not appear to be any evidence of fraud or overreaching, but did not take any position as to whether the requested amount was reasonable. (Docket # 24).

DISCUSSION

I. Timeliness of the Motion Applications for attorneys’ fees generally must be filed within 14 days after the entry of judgment. See Fed. R. Civ. P. 54(d)(2)(B)(1). With respect to attorneys’ fees sought pursuant to § 406(b), the party seeking such fees must file the motion within 14 days of notice of a benefits award. See Sinkler v. Berryhill, 932 F.3d 83, 88 (2d Cir. 2019). It is presumed that a notice is received “three days after mailing.” See id. at 89 n.5; see also Fed. R. Civ. P. 6(d). In this case, the Commissioner issued two Notices of Award, one relating to plaintiff’s SSI claims and one relating to plaintiff’s DIB claims. (Docket ## 21-3; 21-4). Although plaintiff first received her SSI notice on or about September 8, 2022, the Commissioner did not issue a notice relating to plaintiff’s DIB benefits until February 14, 2023. (Docket ## 21-3; 21-4). It was only after the notice for plaintiff’s DIB benefits was issued that counsel was able to ascertain the total amount of past-due benefits and the maximum attorneys’ fees that could be sought. The pending motion was filed on March 1, 2023 – 15 days after the last notice was

issued. Considering the presumption that the notice is received three days after mailing, I conclude that the motion is timely. See Leonard J.H. v. Comm’r of Soc. Sec., 2023 WL 2768300, *2 (W.D.N.Y. 2023) (“the limitations period did not begin until counsel received copies of the Child Auxiliary Notices of Award”) (internal citation omitted); Capers v. Saul, 2022 WL 3543569, *3 (E.D.N.Y. 2022) (“[w]ithout information regarding her child’s award, [p]laintiff’s counsel did not receive notice of the maximum attorney’s fees that may be claimed, and, therefore, the fourteen- day limitations period did not begin to run on that date”) (internal quotation omitted); Kraft v. Comm’r of Soc. Sec., 2021 WL 1540502, *2 (W.D.N.Y. 2021) (attorneys’ fees application was timely when “counsel did not receive notice of the maximum attorney’s fees that may be claimed until the Administration transmitted to her notice of [p]laintiff's children’s award”) (internal

quotation omitted.

II. Reasonableness of the Fees Section 406(b) of the Social Security Act provides, in relevant part: Whenever a court renders a judgment favorable to a claimant under this subchapter who was represented before the court by an attorney, the court may determine and allow as part of its judgment a reasonable fee for such representation, not in excess of 25 percent of the total of the past-due benefits to which the claimant is entitled by reason of such judgment.

42 U.S.C. § 406(b)(1)(A). “The Commissioner’s failure to oppose this motion is not dispositive, as ‘[S]ection 406(b) requires an affirmative judicial finding that the fee allowed is ‘reasonable.’’” Ewald v. Comm’r of Soc. Sec., 2008 WL 4104458, *1 n.1 (E.D.N.Y. 2008) (quoting Gisbrecht v. Barnhart, 535 U.S. 789, 807 n.17 (2002)). “[W]here there is a contingency fee agreement in a successful social security case, the district court’s determination of a reasonable fee under § 406(b) must begin with the agreement, and the district court may reduce the amount called for

by the contingency agreement only when it finds the amount to be unreasonable.” Wells v. Sullivan, 907 F.2d 367, 371 (2d Cir. 1990). While a court “must give due deference to the intent of the parties[,] . . . it ought not blindly approve every fee request made pursuant to a contingent agreement.” Id. at 372; accord Joslyn v. Barnhart, 389 F. Supp. 2d 454, 456 (W.D.N.Y. 2005) (“[a] contingent-fee agreement is not per se reasonable”). In assessing reasonableness, the court should determine “whether the contingency percentage is within the 25% cap [of Section 406(b)]” and “whether there has been fraud or overreaching in making the [contingency] agreement.” Wells v. Sullivan, 907 F.2d at 372. The court should also consider: (1) the “character of the representation and the results the representative achieved”; (2) whether “the attorney [was] responsible for delay . . . so that the

attorney will not profit from the accumulation of benefits during the pendency of the case in court”; and, (3) whether the “benefits are large in comparison to the amount of time counsel spent on the case,” so as to prevent counsel from receiving a windfall. See Gisbrecht v. Barnhart, 535 U.S. at 808.

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Related

Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Joslyn v. Barnhart
389 F. Supp. 2d 454 (W.D. New York, 2005)
Sinkler v. Berryhill
932 F.3d 83 (Second Circuit, 2019)

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Bayer v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bayer-v-commissioner-of-social-security-nywd-2024.