Carlson v. Commissioner of Social Security

CourtDistrict Court, C.D. Illinois
DecidedJanuary 23, 2025
Docket4:24-cv-04144
StatusUnknown

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

Bluebook
Carlson v. Commissioner of Social Security, (C.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF ILLINOIS ROCK ISLAND DIVISION

KERRY C., ) ) Plaintiff, ) ) v. ) Case No. 4:24-cv-04144-SLD ) CAROLYN W. COLVIN, Acting ) Commissioner of Social Security,1 ) ) Defendant. )

ORDER Before the Court is Plaintiff Kerry C.’s Motion for Attorney Fees Pursuant to 28 U.S.C. § 2412(d), ECF No. 11. For the reasons that follow, the motion is GRANTED. BACKGROUND Kerry filed her Complaint on August 5, 2024, seeking judicial review of the Commissioner of Social Security’s (“the Commissioner”) final decision denying her claim for disability benefits. Compl. 1, ECF No. 1. On September 18, 2024, Kerry and the Commissioner filed a joint stipulation stating that the decision denying Kerry’s request for benefits should be reversed and remanded. Joint Stipulation Remand Comm’r 1, ECF No. 8. The Court construed the stipulation as a motion to remand, which it granted pursuant to sentence four of 42 U.S.C. § 405(g). Oct. 9, 2024 Order 1–2, ECF No. 9. Judgment was entered on October 15, 2024. Judgment, ECF No. 10. Kerry filed her motion for attorney’s fees on December 27, 2024. Mot. Att’y Fees 1. The Commissioner does not oppose the motion. Resp. Mot. Att’y Fees 1, ECF No. 13.

1 Pursuant to Federal Rule of Civil Procedure 25(d), Carolyn W. Colvin is substituted for her predecessor. The Clerk is directed to update the docket accordingly. DISCUSSION I. Attorney’s Fees Under the Equal Access to Justice Act Under the Equal Access to Justice Act (“EAJA”), a litigant who is successful in her suit against the federal government is entitled to recover her attorney’s reasonable fees if: (1) she is a

“prevailing party”; (2) the government’s position was not “substantially justified”; (3) there exist no special circumstances that would make an award unjust; and (4) she filed a timely application with the district court. 28 U.S.C. § 2412(d)(1); Krecioch v. United States, 316 F.3d 684, 687 (7th Cir. 2003). First, Kerry is a “prevailing party” within the meaning of the EAJA by virtue of having had judgment entered in her favor and her case remanded to the Commissioner for further review. See Shalala v. Schaefer, 509 U.S. 292, 301 (1993) (finding that a remand “which terminates the litigation with victory for the plaintiff” confers prevailing party status under the EAJA); Tex. State Tchrs. Ass’n v. Garland Indep. Sch. Dist., 489 U.S. 782, 791–92 (1989) (deeming prevailing party status appropriate when “the plaintiff has succeeded on ‘any

significant issue in litigation which achieve[d] some of the benefit the parties sought in bringing suit’” (alteration in original) (quoting Nadeau v. Helgemoe, 581 F.2d 275, 278–79 (1st Cir. 1978))). Second, Kerry’s motion is timely. Section 2412(d)(1)(B) requires that a party seeking an award of fees submit to the court an application for fees and expenses within thirty days of final judgment in the action. The term “final judgment” refers to judgments entered by a court of law, not decisions rendered by an administrative agency. Melkonyan v. Sullivan, 501 U.S. 89, 95–96 (1991). In Social Security cases involving a remand, the filing period for attorney’s fees does not begin until the judgment is entered by the court, the appeal period has run, and the judgment has thereby become unappealable and final. Id. at 102; Schaefer, 509 U.S. at 302 (“An EAJA application may be filed until thirty days after a judgment becomes ‘not appealable’—i.e., thirty days after the time for appeal has ended.”). Judgment was entered on October 15, 2024, and Kerry filed her motion on December 27, 2024, seventy-three days later. Either party would have

had sixty days to appeal, see Fed. R. App. P. 4(a)(1)(B) (providing that where one party is a United States officer sued in an official capacity, the parties have sixty days to appeal), plus the thirty-day allowance in accordance with § 2412(d)(1)(B). Thus, Kerry had to file her motion within ninety days of entry of judgment. Because Kerry’s motion falls within this window, the Court finds that the request is timely. Third, the Commissioner’s position was not “substantially justified.” EAJA fees may be awarded if either the Commissioner’s litigation position or pre-litigation conduct lacked substantial justification. Golembiewski v. Barnhart, 382 F.3d 721, 724 (7th Cir. 2004). For the Commissioner’s position to have been substantially justified, it must have had reasonable factual and legal bases and a reasonable connection between the facts and legal theory. Cunningham v.

Barnhart, 440 F.3d 862, 864 (7th Cir. 2006). Critically, the Commissioner has the burden of proving that the position was substantially justified. Golembiewski, 382 F.3d at 724. Here, Kerry implies that the Commissioner’s position was not substantially justified because the Commissioner agreed that a remand was required in this case. Mot. Att’y Fees 5–6. The Commissioner does not oppose Kerry’s motion, see Resp. Mot. Att’y Fees 1, so the Court finds that the Commissioner’s position was not substantially justified. Finally, no special circumstances exist that would make an award of attorney’s fees unjust. Therefore, Kerry is entitled to recover reasonable attorney’s fees under the EAJA. II. Reasonableness of Kerry’s Attorney’s Fees It is a successful litigant’s burden to prove that the attorney’s fees she requests are reasonable. Hensley v. Eckerhart, 461 U.S. 424, 437 (1983). Reasonable fees are calculated by multiplying the appropriate number of hours worked by a reasonable hourly rate. Id. at 433. The

rate is calculated with reference to prevailing market rates and capped at $125/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,” warrants a higher hourly rate. 28 U.S.C. § 2412(d)(2)(A). The Seventh Circuit has set forth the following standard for EAJA claimants seeking a higher hourly rate: An EAJA claimant seeking a cost-of-living adjustment to the attorney fee rate . . . may rely on a general and readily available measure of inflation such as the Consumer Price Index, as well as proof that the requested rate does not exceed the prevailing market rate in the community for similar services by lawyers of comparable skill and experience. An affidavit from a single attorney testifying to the prevailing market rate in the community may suffice to meet that burden.

Sprinkle v.

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Shalala v. Schaefer
509 U.S. 292 (Supreme Court, 1993)
Astrue v. Ratliff
560 U.S. 586 (Supreme Court, 2010)
Jayne Mathews-Sheets v. Michael Ast
653 F.3d 560 (Seventh Circuit, 2011)
Edward Krecioch v. United States
316 F.3d 684 (Seventh Circuit, 2003)
Melkonyan v. Sullivan
501 U.S. 89 (Supreme Court, 1991)
Stephen Sprinkle v. Carolyn Colvin
777 F.3d 421 (Seventh Circuit, 2015)

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Carlson v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carlson-v-commissioner-of-social-security-ilcd-2025.