Fetters v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedSeptember 16, 2020
Docket3:18-cv-08356
StatusUnknown

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

Bluebook
Fetters v. Commissioner of Social Security Administration, (D. Ariz. 2020).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Robert Ogden Fetters, II, No. CV-18-08356-PCT-MTL

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Before the Court is Plaintiff Robert Fetters’ Motion for Attorney Fees Under the 16 Equal Access to Justice Act (“EAJA”) (Doc. 25) and Mr. Fetters’ Motion for Attorney Fees 17 Under 42 U.S.C. § 406(b) (Doc 29). For the following reasons, the Court grants both 18 motions and awards a total of $39,409.09 in attorney’s fees. 19 I. BACKGROUND 20 Mr. Fetters filed a Complaint requesting judicial review of an Administrative Law 21 Judge’s (“ALJ”) decision denying his application for Social Security Disability Insurance. 22 (Doc. 1.) The Court entered an Order reversing the ALJ’s decision and remanding the case 23 to the Social Security Administration for a calculation of benefits. (Doc. 23.) Judgment 24 was issued on the same day. (Doc. 24.) On April 21, 2020, Plaintiff filed a Motion for 25 Attorney Fees Under the Equal Access to Justice Act (“EAJA”) and a Memorandum in 26 support thereof. (Docs. 25, 26.) Plaintiff’s counsel seeks $10,267.34 in attorney’s fees.1 27 1 Plaintiff’s motion initially sought $9,446.34 in attorney’s fees. (Doc. 25 at 2). Plaintiff 28 amended the amount requested to $10,267.34 based on additional hours spent to complete the reply brief. (Doc. 28 at 10.) 1 Defendant Commissioner of Social Security Administration (the “Commissioner”) does 2 not oppose granting fees under the EAJA but does oppose the amount requested. (Doc 27.) 3 On June 10, 2020, Plaintiff also filed a Motion for Attorney Fees Under 42 U.S.C. § 406(b) 4 and a Memorandum in support thereof. (Docs 29, 30.) Plaintiff’s counsel also seeks 5 $29,141.75 in attorney’s fees for representing Plaintiff on a contingent-fee basis. The 6 Commissioner declined to state a position on the reasonableness of Plaintiff’s requested 7 fees under Section 406(b). (Doc 31.) 8 II. LEGAL STANDARD 9 In a civil action against the United States, except a tort action, the EAJA provides 10 that “a court shall award to a prevailing party other than the United States fees and other 11 expenses . . . unless the court finds that the position of the United States was substantially 12 justified or that special circumstances make an award unjust.” 28 U.S.C. § 2412(d)(1)(A); 13 Tobeler v. Colvin, 749 F.3d 830, 832 (9th Cir. 2014). “‘Substantial justification’ under the 14 EAJA means that the government’s position must have a reasonable basis in law and fact.” 15 Corbin v. Apfel, 149 F.3d 1051, 1052 (9th Cir. 1998). In other words, the government’s 16 position must have been “justified to a degree that could satisfy a reasonable person.” 17 Pierce v. Underwood, 487 U.S. 552, 565 (1988). The government must “demonstrate that 18 both its litigation position and the agency decision on review were substantially justified.” 19 Campbell v. Astrue, 736 F.3d 867, 868 (9th Cir. 2013). 20 Fees awarded under the EAJA must be reasonable. See 28 U.S.C. § 2412(d)(2)(A). 21 A reasonable fee does not include hours that are “excessive, redundant, or otherwise 22 unnecessary.” Hensley v. Eckerhart, 461 U.S. 424, 434. “[T]he fee applicant bears the 23 burden of establishing entitlement to an award and documenting the appropriate hours 24 expended and hourly rates.” Id. at 437. “[A] district court [retains] substantial discretion 25 in fixing the amount of an EAJA award.” Comm’r of INS v. Jean, 496 U.S. 154, 163 26 (1990). Courts generally “defer to the ‘winning lawyer’s professional judgment as to how 27 much time he was required to spend on the case.’” Costa v. Commr. of Soc. Sec. Admin., 28 690 F.3d 1132, 1136 (9th Cir. 2012) (citation omitted). 1 Attorneys who successfully represent Social Security benefits claimants can also 2 recover fees under Section 406(b) of the Social Security Act. 42 U.S.C. § 406(b)(1)(A). 3 Section 406(b) provides that “[w]henever a court renders a judgment favorable to a 4 claimant . . . who was represented by an attorney, the court may determine and allow as 5 part of its judgment a reasonable fee for such representation, not in excess of 25 percent of 6 the total of the past-due benefits.” Id. The fee remains payable “out of, and not in addition 7 to, the amount of [the] past-due benefits.” Id. The Act’s 25-percent statutory cap on the 8 fee does not preclude attorneys and claimants from entering into contingent-fee 9 agreements. Gisbrecht v. Barnhart, 535 U.S. 789, 807 (2002). “Courts [must] approach 10 fee determinations by looking first to the contingent-fee agreement, then testing it for 11 reasonableness.” Id. at 808. District courts may properly reduce the amount requested 12 under a contingent-fee agreement for “substandard performance, delay, or benefits that are 13 not in proportion to the time spent on the case.” Crawford v. Astrue, 586 F.3d 1142, 1151 14 (9th Cir. 2009) (en banc). The burden rests on the attorney “to show that the fee sought is 15 reasonable for the services rendered.” Gisbrecht, 535 U.S. at 807. 16 If an attorney receives fees under both the EAJA and Section 406(b) of the Social 17 Security Act, the claimant’s attorney must “refund to the claimant the amount of the smaller 18 fee.” Id. at 796 (2002) (citation and alteration omitted). See also Russell v. Sullivan, 930 19 F.2d 1443, 1446 (9th Cir. 1991) (holding that dual fee awards under the EAJA and Section 20 406(b) are proper “as long as [Plaintiff’s] attorney gives the smaller of the two awards to 21 his client”). 22 III. ANALYSIS 23 A. EAJA 24 Since the Court remanded his Social Security case to the Commissioner for an award 25 of benefits, Mr. Fetters is considered a prevailing party for purposes of the EAJA. See 26 Shalala v. Schaefer, 509 U.S. 292, 300-01 (1993). Defendant does not contend that the 27 government’s litigation position or underlying agency decision was substantially justified. 28 (Doc. 27.) Therefore, the Court finds that granting fees to Plaintiff under the EAJA is 1 proper. 2 Although Defendant does not claim that the agency’s position was substantially 3 justified, Defendant argues that the amount of fees requested under the EAJA is excessive. 4 (Doc. 27 at 2.) Plaintiff requests $10,267.34 in attorney’s fees for 50.1 hours of services 5 rendered in the case. (Doc. 26-2; Doc 28 at 10.) Defendant questions the reasonableness 6 of the time spent on the case by Plaintiff’s counsel given that the issues raised “were not 7 novel or unique” and Plaintiff’s use of “boilerplate language” in his briefs. (Id.

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Shalala v. Schaefer
509 U.S. 292 (Supreme Court, 1993)
Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Moreno v. City of Sacramento
534 F.3d 1106 (Ninth Circuit, 2008)
Crawford v. Astrue
586 F.3d 1142 (Ninth Circuit, 2009)
Jill Campbell v. Michael Astrue
736 F.3d 867 (Ninth Circuit, 2013)
Craig Tobeler v. Carolyn W. Colvin
749 F.3d 830 (Ninth Circuit, 2014)
Corbin v. Apfel
149 F.3d 1051 (Ninth Circuit, 1998)

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Fetters v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fetters-v-commissioner-of-social-security-administration-azd-2020.