Bresnahan v. Social Security, Commissioner of

CourtDistrict Court, E.D. Michigan
DecidedJuly 29, 2025
Docket2:22-cv-12370
StatusUnknown

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

Bluebook
Bresnahan v. Social Security, Commissioner of, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

LINDSEY B.,

Plaintiff, Case No. 2:22-cv-12370 Hon. Anthony P. Patti V.

COMMISSIONER OF SOCIAL SECURITY,

Defendant. ______________________________________________/

OPINION AND ORDER GRANTING PLAINTIFF’S COUNSEL’S PETITION FOR AWARD OF ATTORNEY FEE PURSUANT TO 42 U.S.C. § 406(b) (ECF No. 16)

I. INTRODUCTION A. Procedural Background On October 5, 2022, Lindsay B. (“Plaintiff”) commenced this action, via counsel, for judicial review of the Commissioner’s unfavorable decision. (ECF No. 1.) On February 6, 2023, the Court entered a stipulated order to remand (ECF No. 13) and entered judgment remanding the matter to the Social Security Administration (SSA) for further administrative proceedings (ECF No. 14). On March 7, 2023, the Court entered a stipulation and order awarding attorney fees in the amount of $7,000 under the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412. (ECF No, 15.) Plaintiff’s counsel reports that, thereafter, an Administrative Law Judge (ALJ) issued a favorable decision finding the Plaintiff “became

disabled under [the Social Security Administration’s] rules on August 24, 2019” (ECF No. 16, PageID.1392; ECF No. 16-2, PageID.1402). On October 28, 2024, the SSA informed Plaintiff that he was “entitled to

monthly disability benefits . . . beginning February 2020.” (ECF No. 16-2, PageID.1401.) Inter alia, the SSA noted it was “taking Part B (Medical Insurance) premiums due through October 2024 out of the check” in the amount of $174.70. (Id., PageID.1403.) The SSA also explained that it withheld “$16,535.00 from

[her] past due benefits in case [it] need[ed] to pay [her] representative[,]” i.e., an assumed 25% contingent fee. (Id., PageID.1404.) B. The Instant Motion

On November 7, 2024, Attorney Bryan Konoski filed a petition for award of attorney fee pursuant to 42 U.S.C. § 406(b) (ECF No. 16), requesting “an award of attorney’s fees in the amount of $16,535.00, reduced by the original EAJA fee award of $7,000, for a NET TOTAL FEE of $9,535.00” (id., PageID.1391) in

accordance with the contingent fee contract into which Plaintiff and Attorney Konoski entered on August 27, 2022 (ECF No. 16-2). (ECF No. 16, PageID.1393.) In the Commissioner’s response, the Commissioner states that it “neither supports nor opposes counsel’s request for attorney’s fees in the amount of

$9,535.00,1 under 42 U.S.C. § 406(b)” (ECF No. 17, PageID.1414).2 The Commissioner notes that it takes “no position on the request to award a netted 406(b) award.” (Id., PageID.1416.) The Commissioner further points out that if

the Court grants counsel’s request to award a net fee, rather than requiring counsel to refund the previously received EAJA fee, then the Court’s reasonableness determination under section 406(b) must be based on the full amount of fees sought, not the net fee after offset. The Commissioner requests that the Order

distinguish between the full amount found reasonable under section 406(b) and the net amount awarded for payment purposes. (Id.) The Court does so below.

1 The Commissioner notes that “Plaintiff moves for an attorney fee of $16,535.00, reduced by the Equal Access to Justice Act (EAJA) fee of $7,000.00 for a net total fee of $9,535.00.” (ECF No. 17, PageID.1414, citing ECF No. 16, PageID.1392.)

2 The Commissioner also mentions in a footnote that the Plaintiff’s motion did not indicate “what if any fees are being sought under 42 U.S.C. 406(a) as required by Local Rule 54.2(b)(4).” (ECF No. 17, PageID.1414, n.2.) Indeed, Plaintiff’s motion did not include any request for fees pursuant to 42 U.S.C. 406(a), as that provision was never referenced and no such fees appear to be sought (ECF No. 16). However, the Local Rule does not specifically reference subpart “a” of the statute; rather, it refers to § 406 as a whole. It is obvious to the Court from Petitioner’s supporting time records (ECF No. 16-2) that the fees sought only relate to representation before the Court, under subsection “b,” not to representation before the Commissioner under subsection ”a.” Pursuant to Administrative Order 22-AO-035, this case was assigned to me. On January 12, 2023, the parties filed a Joint Statement Regarding Consent,

confirming that both consented to my presiding. (ECF No. 10.) II. Discussion While the Commissioner does not oppose the amount sought, the Court has

an independent obligation to assess the reasonableness of a request for attorney fees under the statute. See Gisbrecht v. Barnhart, 535 U.S. 789, 807 (2002); see also Lasley v. Commissioner of Social Sec., 711 F.3d 308, 310 (6th Cir. 2014). Indeed, as the Sixth Circuit has noted, “[t]he primary concern in an attorney fee

case is that the fee awarded be reasonable, that is, one that is adequately compensatory to attract competent counsel yet which avoids producing a windfall for lawyers.” Adcock-Ladd v. Sec’y of Treasury, 227 F.3d 343, 349 (6th Cir.

2000). “The party requesting attorney fees bears the burden of establishing the number of hours and hourly rate are reasonable.” Hensley v. Eckerhart, 461 U.S. 424, 437 (1983). A reasonable hourly rate is the rate “prevailing in the community for similar

services by lawyers of reasonably comparable skill, experience, and reputation.” Hadix v. Johnson, 65 F.3d 532, 536 (6th Cir. 1995) (quoting Blum v. Stenson, 465 U.S. 886, 896 n.11, (1984)). “In order to determine the local market rate, the court

should rely on a combination of its own expertise and judgment.” Stryker Corp. v. Prickett, No. 1:14-01000, 2016 U.S. Dist. LEXIS 167120, at *8 (W.D. Mich. Dec. 5, 2016). The court may consider proof of rates charged in the community under

similar circumstances, as well as opinion evidence of reasonable rates, Wells v. Corporate Accounts Receivable, 683 F.Supp.2d 600, 602 (W.D. Mich. 2010), and the benchmark for determining a reasonable hourly rate is the State Bar of

Michigan’s Economics of Law Practice Survey. See Lamar Advertising Co. v. Charter Twp. of Van Buren, 178 F.App’x 498, 501-02 (6th Cir. 2006). “The district court has broad discretion in determining a reasonable hourly rate for an attorney.” Northeast Ohio Coal. for the Homeless v. Husted, 831 F.3d 686, 715

(6th Cir. 2016). When analyzing large hourly fees, the Sixth Circuit has held that a 25% fee award is presumed reasonable. See Rodriquez v. Bowen, 865 F.2d 739, 746 (6th

Cir. 1989).

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Blum v. Stenson
465 U.S. 886 (Supreme Court, 1984)
Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Everett Hadix v. Perry Johnson
65 F.3d 532 (Sixth Circuit, 1995)
United States v. Botti
711 F.3d 299 (Second Circuit, 2013)
Wells v. CORPORATE ACCOUNTS RECEIVABLE
683 F. Supp. 2d 600 (W.D. Michigan, 2010)
Northeast Ohio Coalition for the Homeless v. Husted
831 F.3d 686 (Sixth Circuit, 2016)
Rodriquez v. Bowen
865 F.2d 739 (Sixth Circuit, 1989)

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