Brett Michael Peterson v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedApril 2, 2026
Docket1:23-cv-00684
StatusUnknown

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

Bluebook
Brett Michael Peterson v. Commissioner of Social Security, (E.D. Cal. 2026).

Opinion

7 UNITED STATES DISTRICT COURT 8 9 EASTERN DISTRICT OF CALIFORNIA 10 BRETT MICHAEL PETERSON, Case No. 1:23-cv-00684-SAB 11 Plaintiff, ORDER GRANTING PETITIONERS’ 12 MOTION FOR ATTORNEY’S FEES v. PURSUANT TO 42 U.S.C. § 406(b) 13 COMMISSIONER OF SOCIAL SECURITY, 14 (ECF No. 30) Defendant. 15 16 Before the Court is a motion for attorney’s fees brought by Petitioners Jonathan O. Peña 17 and Dolly M. Trompeter, attorneys for Brett Michael Petersen1 (“Plaintiff”). Petitioners requests 18 fees in the amount of $22,427.00 pursuant to 42 U.S.C. § 406(b)(1). Petitioners also request they 19 be directed to reimburse Plaintiff the Equal Access Justice Act (“EAJA”) fee awarded in full, 20 $8,119.33. 21 Plaintiff did not file an opposition or otherwise respond to the motion for attorney’s fees, 22 and the time to do so has passed. Defendant Commissioner of Social Security, as a de facto 23 trustee for Plaintiff, filed a response to Petitioners’ motion, in which he asserts he neither 24 supports nor opposes Petitioners’ request for attorney’s fees, but observes that the Court should 25 direct Petitioners to reimburse Plaintiff any fees they previously received under the EAJA. (ECF 26 No. 33.)

27 1 It appears that when the case was opened, the Clerk of the Court entered Plaintiff’s last name as “Peterson” as a scrivener’s error. (See ECF No. 1.) Because the caption has not been subsequently updated, the Court leaves it as is 1 I. 2 BACKGROUND 3 On October 1, 20202, and again on April 23, 2023, Plaintiff entered into a contingent fee 4 agreement with the Jonathan O. Peña and Dolly M. Trompeter, attorneys at law. (ECF No. 30- 5 3.) The agreements entitled Petitioners to an award of 25 percent of the past-due benefits 6 awarded, including if judicial review of an administrative decision were required and the adverse 7 decision of an ALJ were reversed. (Id.) 8 On October 13, 2020, Plaintiff filed a complaint in this Court, before the Hon. Jennifer L. 9 Thurston, then-United States Magistrate Judge, challenging the denial of social security benefits. 10 Petersen v. Commissioner of Social Security, No. 1:20-cv-01459-JLT, ECF No. 1 (E.D. Cal. Oct. 11 13, 2020). On July 20, 2021, the parties file a stipulation for voluntary remand pursuant to 12 Sentence Four of 42 U.S.C. § 405(g). Id. at ECF No. 16. Judge Thurston approved the 13 stipulation, ordered the matter be remanded back to the agency, and directed the Clerk of the 14 Court to enter judgment. Id. at ECF Nos. 17, 18. On November 5, 2021, the parties stipulated to 15 an award of attorney’s fees in the amount of $919.33 under the EAJA, 28 U.S.C. § 2412, which 16 Judge Thurston approved. Id. at ECF Nos. 19, 20. 17 Following a subsequent final decision from the Commissioner, on May 4, 2023, Plaintiff 18 filed a complaint before the undersigned challenging the denial of social security benefits. (ECF 19 No. 1.) Following the lodging of the social security administrative record and briefing related to 20 judicial review (ECF Nos. 11, 18, 22, 23), on July 7, 2024, the Court reversed and remanded the 21 final decision of the Commissioner and directed the Clerk of the Court to enter judgment. (ECF 22 Nos. 24, 25.) On October 4, 2024, the parties stipulated to an award of attorney’s fees in the 23 amount of $7,200.00 under the EAJA, 28 U.S.C. § 2412, which the Court approved. (ECF No. 24 27, 29.) 25 Ultimately, on or around March 4, 2026, Plaintiff became a prevailing party. (ECF No. 26 30-2.) In the instant motion, Petitioners seek an award of attorney’s fees in the amount of 27 $22,427.00, pursuant to 42 U.S.C. § 406(b) and an order to reimburse Plaintiff the amount 1 proceedings in 2021 and 2024). (ECF No. 34.) 2 II. 3 LEGAL STANDARD 4 In relevant part, 42 U.S.C. § 406(b)(1)(A) provides that when a federal court “renders a 5 judgment favorable to a claimant . . . who was represented before the court by an attorney,” the 6 court may allow reasonable attorney fees “not in excess of 25 percent of the total of the past-due 7 benefits to which the claimant is entitled by reason of such judgment.” The payment of such 8 award comes directly from the claimant’s benefits. 42 U.S.C. § 406(b)(1)(A). 9 The Supreme Court has explained that a district court reviews a petition for section 10 406(b) fees “as an independent check” to assure that the contingency fee agreements between the 11 claimant and the attorney will “yield reasonable results in particular cases.” Gisbrecht v. 12 Barnhart, 535 U.S. 789, 807 (2002). The district court must respect “the primacy of lawful 13 attorney-client fee agreements,” and is to look first at the contingent-fee agreement, and then test 14 it for reasonableness.” Crawford v. Astrue, 586 F.3d 1142, 1148 (9th Cir. 2009). The twenty- 15 five percent maximum fee is not an automatic entitlement, and courts are required to ensure that 16 the requested fee is reasonable. Gisbrecht, 535 U.S. at 808-09. The attorney has the burden of 17 demonstrating that the fees requested are reasonable. Id. at 808; Crawford, 586 F.3d at 1148. 18 In determining the reasonableness of an award, the district court should consider the 19 character of the representation and the results achieved. Gisbrecht, 535 U.S. at 800. Ultimately, 20 an award of section 406(b) fees is offset by an award of attorney’s fees granted under the EAJA. 21 Id. at 796. The Ninth Circuit has identified several factors that a district court can examine under 22 Gisbrecht in determining whether the fee was reasonable. In determining whether counsel met 23 his burden to demonstrate that the requested fees are reasonable, the court may consider (1) the 24 standard of performance of the attorney in representing the claimant; (2) whether the attorney 25 exhibited dilatory conduct or caused excessive delay which resulted in an undue accumulation of 26 past-due benefits; and (3) whether the requested fees are excessively large in relation to the 27 benefits achieved when taking into consideration the risk assumed in these cases. Crawford, 586 1 III. 2 DISCUSSION 3 A. Attorney Fees Under 42 U.S.C. § 406(b) 4 The Court begins with Plaintiff’s agreements to pay 25% of the past-due benefits 5 awarded following both for representation in the federal courts and in receiving a favorable 6 decision on his applications. (ECF No. 30-3.) The Court recognizes the contingent nature of this 7 case and counsel’s assumption of the risk of going uncompensated. Hearn v. Barnhart, 262 F. 8 Supp. 2d 1033, 1037 (N.D. Cal. 2003). The Social Security Administration notified Plaintiff that 9 “[w]e usually withhold 25 percent of past due benefits in order to pay the approved 10 representative’s fee. We withheld $22,427.00 from your past due benefits in case we need to pay 11 your representative.” (ECF No. 30-2, p. 4.) Petitioners now seek $22,427.00, which is precisely 12 25 percent. (ECF No.

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Related

Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Crawford v. Astrue
586 F.3d 1142 (Ninth Circuit, 2009)
Dye v. United States
262 F. 6 (Fourth Circuit, 1919)

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Brett Michael Peterson v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brett-michael-peterson-v-commissioner-of-social-security-caed-2026.