Bynum v. Commissioner of Social Security

CourtDistrict Court, M.D. Florida
DecidedJuly 1, 2025
Docket8:24-cv-02766
StatusUnknown

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

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Bynum v. Commissioner of Social Security, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

TAMMI BYNUM,

Plaintiff,

v. Case No. 8:24-cv-2766-CPT

FRANK BISIGNANO, Commissioner of Social Security,1

Defendant. ____________________________/

O R D E R Before the Court is the Plaintiff’s unopposed amended motion for attorneys’ fees pursuant to the Equal Access to Justice Act (EAJA or the Act). (Doc. 23). For the reasons discussed below, the Plaintiff’s motion is granted in part and denied in part. I. The Plaintiff initiated this action in November 2024 seeking judicial review of the Commissioner’s decision denying her application for Disability Insurance Benefits. (Doc. 1). In March 2025, the Court reversed the Commissioner’s decision and

1 Mr. Bisignano became the Commissioner of Social Security on May 6, 2025. Pursuant to Federal Rule of Civil Procedure 25(d), Mr. Bisignano is substituted for the former Acting Commissioner, Mr. Leland Dudek, as the Defendant in this suit. remanded the case for further proceedings. (Doc. 18). The Clerk of Court entered Judgment for the Plaintiff several days later. (Doc. 19). The instant motion, uncontested by the Commissioner, followed. (Doc. 23).

II. The EAJA authorizes a court to grant attorneys’ fees to any party prevailing in litigation against the United States (including proceedings for judicial review of agency action), unless the court determines that the government’s position was “substantially justified” or that special circumstances exist which make such an award unjust. 28

U.S.C. § 2412(d). To warrant the issuance of fees under the Act, three conditions must be met: (1) a party must file a fee application within thirty days of the final judgment; (2) a party must qualify as the prevailing party and her net worth must not have exceeded $2,000,000 at the time she commenced the action; and (3) the government’s position must not have been substantially justified and there must be no other special

circumstances that would render such an award unjust. Id.; Patton v. Berryhill, 2017 WL 6520474, at *1 (M.D. Fla. Dec. 18, 2017) (citing Myers v. Sullivan, 916 F.2d 659, 666–67 (11th Cir. 1990)). Each of these conditions has been satisfied here, as the Commissioner

effectively acknowledges by his lack of opposition. Thus, it is appropriate to grant attorneys’ fees pursuant to the EAJA in this case. In assessing the fees to be authorized, courts look to subsection 2412(d)(2)(A), which provides, in pertinent part: The amount of fees [to be] awarded [to the prevailing party in any civil action brought against any agency or any official of the United States] shall be based upon [the] prevailing market rates for the kind and quality of the services furnished, except that . . . attorney[s’] fees shall not be awarded in excess of $125 per hour unless the court determines that an increase in the cost of living or a special factor, such as the limited availability of qualified attorneys for the proceedings involved, justifies a higher fee.

28 U.S.C. § 2412(d)(2)(A). As reflected by this statutory language, an analysis of the proper hourly rate under the Act consists of two steps. First, a court must ascertain the market rate for similar services provided by lawyers of comparable skill, experience, and reputation. Meyer v. Sullivan, 958 F.2d 1029, 1033 (11th Cir. 1992) (quoting Norman v. Hous. Auth. of Montgomery, 836 F.2d 1292, 1299 (11th Cir. 1988)). Second, if the prevailing market rate is more than $125 per hour, a court must decide whether to adjust the hourly rate for an increase in the cost of living or some special factor. Id. at 1033–34. The market rate during the relevant period for the type of work at issue in this case is not subject to precise calculation. In the Court’s experience, counsel submitting EAJA fee petitions for services performed since 2020 have typically sought hourly rates exceeding $200. As a result, the hourly rate charged by competent attorneys in this market has, for some time, surpassed the statutory cap of $125. The Court is not alone in this observation. See, e.g., Roman v. Comm’r of Soc. Sec., 2024 WL 3046249, at *1 (M.D. Fla. June 18, 2024); Goldstein v. Comm’r of Soc. Sec., 2024 WL 2019866, at *1 (M.D. Fla. May 7, 2024); Burke v. Comm’r of Soc. Sec., No. 8:21-cv-1267-MSS-SPF, (Doc. 25) (M.D. Fla. Apr. 25, 2022), report and recommendation adopted, (Doc. 26) (M.D. Fla. May 23, 2022); Chartier v. Comm’r of Soc. Sec., 2022 WL 1289335, at *2 (M.D. Fla. Apr. 29, 2022); Britt v. Comm’r of Soc. Sec., 2022 WL 358674, at *2 (M.D.

Fla. Jan. 27, 2022), report and recommendation adopted, 2022 WL 356218 (M.D. Fla. Feb. 7, 2022). The Court therefore finds there is a sufficient basis to deviate upwardly from the EAJA’s base fee rate to account for increases in the cost of living. Courts in this district and elsewhere routinely compute cost of living

adjustments under the Act by using the Bureau of Labor Statistics’ Consumer Price Index (CPI). See, e.g., Wilborn v. Comm’r of Soc. Sec., 2013 WL 1760259, at *1 (M.D. Fla. Apr. 24, 2013); Rodgers v. Astrue, 657 F. Supp. 2d 1275, 1277 (M.D. Fla. 2009); Morrison v. Astrue, 2010 WL 547775, at *2 (S.D. Fla. Feb. 12, 2010);2 see also Sprinkle v. Colvin, 777 F.3d 421, 428 (7th Cir. 2015) (collecting various circuit court opinions

utilizing the CPI to evaluate hourly rate adjustments). Given this case authority, the Court finds it reasonable to employ the CPI as a guide for determining cost of living increases under the EAJA. See U.S. DEP’T OF LABOR, BUREAU OF LABOR STATISTICS, https://data.bls.gov/cgi-bin/surveymost?bls (last visited June 30, 2025). Here, the Plaintiff asks the Court to award her $3,676.84 in attorneys’ fees for

the services her counsel, Sarah Atkins, George Piemonte, and Ellen Moyle, rendered in this action. (Doc. 23-2). According to the Plaintiff’s submission, Ms. Atkins, Mr.

2 For a discussion of the CPI data employed by many courts in this Circuit, as well as an explanation of the cost of living adjustment calculation, see Sensat v. Berryhill, 2018 WL 5257143, at *6 n.12 (S.D. Fla. Oct. 22, 2018). Piemonte, and Ms. Moyle devoted 1.3 hours, 2.9 hours, and 10.4 hours, respectively, to the case in 2024 and 2025.3 Id. The hourly rate requested for all three lawyers is $251.84. Id..

In light of the Court’s knowledge and experience in addressing fee matters, the Court finds that the amount of time expended by each of the above attorneys is both reasonable and adequately bolstered by the record. See Norman v. Hous. Auth. of City of Montgomery, 836 F.2d 1292, 1303 (11th Cir. 1988); Barreras v. Comm’r of Soc. Sec., 2021

WL 3934269, at *3 (M.D. Fla. Aug. 2, 2021), report and recommendation adopted, 2021 WL 3930507 (M.D. Fla. Sept. 2, 2021). The same is true with respect to the hourly rate claimed by Ms. Atkins. See id. The hourly rate sought for Mr. Piemonte and Ms. Moyle—neither of whom is admitted to practice in this District and neither of whom appeared pro hac vice—is

not so straightforward, however.4 See (Docs. 23-5, 23-6). In Callaway v. Acting Comm’r of Soc. Sec., 802 F. App’x 533 (11th Cir.

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