Danielle Branam v. Frank Bisignano, Acting Commissioner of Social Security

CourtDistrict Court, E.D. Tennessee
DecidedJanuary 28, 2026
Docket1:23-cv-00275
StatusUnknown

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

Bluebook
Danielle Branam v. Frank Bisignano, Acting Commissioner of Social Security, (E.D. Tenn. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT CHATTANOOGA

DANIELLE BRANAM, ) ) Plaintiff, ) ) v. ) Case No. 1:23-CV-275 ) FRANK BISIGNANO, ) Acting Commissioner of Social Security, ) ) Defendant. )

REPORT AND RECOMMENDATION

This matter is before the United States Magistrate Judge pursuant to 28 U.S.C. § 636 and the standing orders of the court, on the motion filed by Plaintiff’s counsel, Bryan Konoski, requesting an award of $23,324.00 in attorney’s fees pursuant to 42 U.S.C. § 406(b). [Doc. 21]. The fees are requested to compensate counsel for work performed on behalf of Plaintiff in pursuit of disability insurance benefits. [Doc. 21]. Counsel notes that fees were previously awarded in this matter under the Equal Access to Justice Act (“EAJA”), 28 U.S.C. § 2412(d). Because counsel was previously awarded $6,500.00 in EAJA fees, in his motion counsel proposes to effectuate the required EAJA refund by reducing the amount of 406(b) fees sought for payment to $16,824.00. The Commissioner filed a Response advising that he neither supports nor opposes the amount of the requested fees but requests that the Court indicate in its order that the amount of fees authorized “is to be paid out of Plaintiff’s past-due benefits in accordance with agency policy.” [Doc. 22]. The response also requests that the “reasonableness determination of the section 406(b) fee request […] be based on the full 406(b) fees sought rather than the net fee awarded after the offset” and that the “[o]rder distinguish between the full amount determined as reasonable under section 406(b) and the net amount awarded for payment purpose.” [Doc. 22, p. 3]. I. PROCEDURAL HISTORY AND BACKGROUND On November 20, 2023, Plaintiff filed a Complaint [Doc. 1] seeking review of the Commissioner’s final decision denying Plaintiff’s application for disability insurance benefits. Then on March 13, 2024, the Court remanded the matter to the Social Security Administration pursuant to sentence four of 42 U.S.C. § 405(g). [Doc. 15]. On May 17, 2024, the parties entered a Joint Stipulation wherein Defendant agreed that Plaintiff was entitled to an award of $6,500.00 in attorney

fees pursuant to the EAJA. [Doc. 17]. Shortly thereafter, Plaintiff filed a Motion for payment of EAJA fees, including a certificate of conferral. [Doc. 18]. Thereafter, the Court entered an Order awarding the amount stipulated by the parties and requested in Plaintiff’s motion. [Doc. 20]. The motion now before the Court seeks an additional award of attorney fees pursuant to 42 U.S.C. § 406(b). [Doc. 21]. At this juncture, Plaintiff’s counsel is requesting attorney fees in the amount of $23,324.00, pursuant to 42 U.S.C. § 406(b) based on a contingency fee agreement with Plaintiff pursuant to which Plaintiff contracted to pay Attorney Konoski up to 25% of the past due benefits award. [Doc. 21-1]. Counsel has attached Plaintiff’s benefits award letter showing that Plaintiff was awarded $73,263.00 in past-due benefits [Doc. 21-1, p. 2], and that twenty-five percent of the total award, or $24,024.00, was withheld to pay legal fees. [Doc. 25]. Because counsel has already been awarded $6,500.00, he

is now seeking $16,824.00, the net remaining amount of the fee award requested after the EAJA award previously received is deducted.1 Counsel submits that this amount is reasonable pursuant to Gisbrecht v. Barnhart, 535 U.S. 789 (2002).

1 Counsel notes that he is seeking less than the full twenty-five percent award because “Konoski & Partners, P.C. only represented the Plaintiff at the federal level” and therefore have no claim for 406(a) fees. [Doc. 21, pg. 3, fn. 1]. III. ANALYSIS Section 406(b) permits courts to award “a reasonable [attorneys’] fee … not in excess of 25 percent,” payable “out of . . . [the claimant’s] past-due benefits” when a claimant secures a favorable judgment. 42 U.S.C. § 406(b)(1)(A). Three conditions must be met before 406(b) fees will be awarded: 1. The Court must have rendered a judgment favorable to the plaintiff; 2. The plaintiff must have been represented by counsel; and

3. The Court must find that the fee is reasonable and does not exceed twenty-five (25) percent of the total past-due benefits to which Plaintiff is entitled.

See id. All three conditions have been satisfied here, and the Court will address each in turn. In this case, Claimant’s Motion for Remand was granted, and the matter was remanded pursuant to sentence four of 42 U.S.C. § 405(g). [Doc. 15]. For purposes of § 406(b), a judgment ordering remand may be considered a favorable judgment so long as the claimant is eventually awarded benefits by reason of the judgment. See 42 U.S.C. § 406(b)(1)(A); see also Bergen v. Comm’r of Soc. Sec., 454 F.3d 1273, 1277 (11th Cir. 2006). Claimant was represented by Attorney Konoski before this Court, and he was successful in helping Plaintiff attain an award of benefits upon remand. Counsel for Claimant submits that the fee requested is appropriate and sought with the agreement of his client. He claims that the time spent on Plaintiff’s case was reasonable in order to provide effective representation and provides case law to support the reasonableness of his fee request. [Doc. 21]. Still, the Court must independently determine whether the requested fee is reasonable. Gisbrecht v. Barhhart, 535 U.S. 789, 807 (2002). While the Sixth Circuit has held that a fee agreement which provides for an attorney to be paid twenty-five percent of the benefits awarded to a plaintiff is presumed reasonable, they have further held that the presumption is rebuttable. Damron v. Comm’r of Soc. Sec., 104 F.3d 853, 856-57 (6th Cir. 1997) (citing Rodriquez, 865 F.2d at 746). The presumption may be overcome by a showing that “1) the attorney engaged in improper conduct or was ineffective, or 2) the attorney would enjoy an undeserved windfall due to the client’s large back pay award or the attorney’s relatively minimal effort.” Hayes v. Sec’y of Health & Human Servs., 923 F.2d 418, 419 (6th Cir. 1990) (citing Rodriquez, 865 F.2d at 746). If neither circumstance applies, “an agreement for a [twenty-five percent] fee … is presumed reasonable.” Id. at 421. The Sixth Circuit “provides a floor” for determining the reasonableness of requested 406(b) fees. Id. at 422. Where the amount requested divided by the number of hours expended is less than twice the standard rate for such work in the relevant market, the requested fee is per se reasonable.

Id.

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Danielle Branam v. Frank Bisignano, Acting Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/danielle-branam-v-frank-bisignano-acting-commissioner-of-social-security-tned-2026.