Dart v. Commissioner of Social Security

CourtDistrict Court, S.D. Georgia
DecidedDecember 30, 2024
Docket6:24-cv-00030
StatusUnknown

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

Bluebook
Dart v. Commissioner of Social Security, (S.D. Ga. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA STATESBORO DIVISION JEROME DART, ) ) Plaintiff, ) ) v. ) CV624-030 ) COMMISSIONER OF SOCIAL ) SECURITY, ) Defendant. ) REPORT AND RECOMMENDATION Plaintiff Jerome Dart seeks attorney’s fees under the Equal Access to Justice Act. Doc. 11. The Defendant does not oppose the motion. Id. at 2. For the reasons set forth below, it is RECOMMENDED1 that plaintiff’s motion be GRANTED. Doc. 11. I. BACKGROUND At the Defendant’s request, the District Judge reversed and remanded plaintiff’s social security appeal to the agency for further consideration, and judgment was entered in plaintiff’s favor. Docs. 8

1 The Federal Rules of Civil Procedure establish that the Court “may refer a motion for attorney’s fees to a magistrate judge under Rule 72(b) as if it were a dispositive pretrial matter.” Fed. R. Civ. P. 54(d)(2)(D). When considering a dispositive pretrial matter assigned “without the parties’ consent,” pursuant to Rule 72, “[t]he magistrate judge must enter a recommended disposition.” Fed. R. Civ. P. 72(b)(1). (Consent Motion for Entry of Judgment Under Sentence Four of 42 U.S.C. § 405(g) with Reversal and Remand); 9 (Remand Order); & 10

(Judgment). Plaintiff then filed the instant motion requesting $12,073.92 in attorney’s fees for 48 hours of time and $405.00 as

reimbursement for the filing fee. Doc. 11 at 1. II. ANALYSIS “Under the EAJA, a party that prevails against the United States

in court may be awarded fees . . . if the government's position in the litigation was not ‘substantially justified.’” Jackson v. Comm'r of Soc. Sec., 601 F.3d 1268, 1271 (11th Cir. 2010) (citing 28 U.S.C.

§ 2412(d)(1)(A)). A plaintiff who wins remand pursuant to sentence four of 42 U.S.C. § 405(g) is a “prevailing party.” Shalala v. Schaefer, 509 U.S. 292, 300-01 (1993). A prevailing party may file a motion for attorney’s

fees under the EAJA up to 90 days after entry of judgment. Newsome v. Shalala, 8 F.3d 775, 779 (11th Cir. 1993). Where an award is appropriate, the Court must also determine whether the number of hours

counsel claims to have expended on the matter, counsel's requested hourly rate, and the resulting fees are all reasonable. See Jean v. Nelson, 863 F.2d 759, 773 (11th Cir. 1988). Plaintiff is a prevailing party, see doc. 9, and his request is timely, see doc. 10 (Judgment entered November 22, 2024), doc. 11 (Motion filed

December 21, 2024). The Commissioner does not contend that the agency’s position was substantially justified. See doc. 11-1 at 2; see also

Stratton v. Bowen, 827 F.2d 1447, 1450 (11th Cir. 1987) (“The government bears the burden of showing that its position was substantially justified.”). The Court should find that Plaintiff is entitled

to an award pursuant to the EAJA. The Court should also find that the requested fees are reasonable. EAJA fees are determined under the “lodestar” method by determining

the number of hours reasonably expended on the matter multiplied by a reasonable hourly rate. Jean, 863 F.2d at 773. In the Eleventh Circuit, “[t]he court, either trial or appellate, is itself an expert on the question

[of attorney’s fees] and may consider its own knowledge and experience concerning reasonable and proper fees . . . .” Norman v. Hous. Auth. Of City of Montgomery, 836 F.2d 1292, 1303 (11th Cir. 1988) (quotation

marks and citations omitted). Under the EAJA, fees are “based upon prevailing market rates for the kind and quality of services furnished,” not to exceed $125 per hour unless the Court determines that an increase in the cost of living or a special factor justifies a higher fee. 28 U.S.C. § 2412(d)(2)(A).

First, the number of hours expended on this case by Plaintiff’s counsel appears reasonable. Counsel requests fees for 48 hours of work,

which counsel indicates is a voluntary reduction to avoid “fee-related litigation.” See doc. 11 at 1; see also doc. 11-4 at 4. The transcript in this case totaled 885 pages, see doc. 5-1 at 1-3, and counsel distilled that

record down into a persuasive brief analyzing nine distinct issues, doc. 6. The brief was so compelling the Defendant sought reversal and remand for further proceedings. See doc. 8. Additionally, the proposed hourly

rate of $251.54, which counsel represents is the $125 statutory cap adjusted for inflation, is reasonable. See doc. 11-1 at 2-4; 28 U.S.C. § 2412(d)(2)(A). Given the reasonableness of the hours expended and the

hourly rate, the Court should award Plaintiff2 $12,073.92 in attorney’s fees.

2 Plaintiff has attached an assignment of EAJA fees from Plaintiff to his counsel. See doc. 11-2. In Astrue v. Ratliff, 560 U.S. 586, 589 (2010), the Supreme Court held that an EAJA award “is payable to the litigant and is therefore subject to a Government offset to satisfy a pre-existing debt that the litigant owes the United States.” Based on Ratliff, the proper course is to “award the EAJA fees directly to Plaintiff as the prevailing party and remain silent regarding the direction of payment of those fees.” Bostic v. Comm'r of Soc. Sec., 858 F. Supp. 2d 1301, 1306 (M.D. Fla. 2011). Therefore, as Plaintiff’s counsel acknowledges, see doc. 11 at 1-2, the Court should award the Plaintiff also seeks reimbursement of filing costs of $405.00. Doc. 11 at 1; see also doc. 11-1 at 5; doc. 1 (documenting Clerk’s receipt of $405

filing fee). Costs under the EAJA, “including fees of the clerk, are reimbursed from the judgment fund administered by the Department of

the Treasury, while attorney fees and expenses are paid by the Social Security Administration.” Rosenthal v. Kijakazi, 2021 WL 4066820, at *1 (M.D. Fla. Aug. 17, 2021), report and recommendation adopted, 2021

WL 4060304 (M.D. Fla. Sep. 7, 2021); see also Perry v. Comm'r of Soc. Sec., 2020 WL 4193515, at *2 (M.D. Fla. July 21, 2020) (finding that the plaintiff's filing fee was a compensable cost under the EAJA). Thus, the

$405 filing fee is recoverable under the EAJA as a cost to be paid from the judgment fund. See 31 U.S.C. § 1304.

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