Gates v. Commissioner of Social Security

District Court, W.D. New York·Decided January 2, 2025·No. 1:20-cv-00656·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK ___________________________________

ASU G.,

Plaintiff, DECISION AND ORDER v. 1:20-cv-00656-EAW COMMISSIONER OF SOCIAL SECURITY,

Defendant. ____________________________________

INTRODUCTION Plaintiff Asu G. (“Plaintiff”) seeks attorneys’ fees in the amount of $31,551.25 pursuant to 42 U.S.C. § 406(b). (Dkt. 21). The Commissioner of Social Security (“the Commissioner”) neither supports nor opposes Plaintiff’s fee request. (Dkt. 25). For the reasons that follow, the Court grants Plaintiff’s motion. BACKGROUND On June 2, 2020, Plaintiff filed this action, seeking review of the Commissioner’s final decision denying his application for Disability Insurance Benefits (“DIB”). (Dkt. 1). Plaintiff moved for judgment on the pleadings on March 30, 2021. (Dkt. 12). On August 26, 2021, the Court approved the parties’ stipulation for remand, reversing the Commissioner’s final decision and remanding the matter for further proceedings. (Dkt. 14). By Stipulated Order filed on October 1, 2021, the Court approved payment of $6,647.86 to Plaintiff’s counsel pursuant to the Equal Access to Justice Act, 28 U.S.C.

§ 2412(d) (“EAJA”), for services performed in connection with this action and $400.00 in costs. (Dkt. 18). On July 22, 2024, the Commissioner issued a Notice of Award in connection with Plaintiff’s DIB claim, which stated that the Commissioner withheld $27,879.50 from Plaintiff’s past-due benefits to pay for Plaintiff’s attorneys’ fees. (Dkt. 21-3 at 3). Two days later—on July 24, 2024—the Commissioner issued four Notices of Award in

connection with Plaintiff’s child auxiliary claims, which stated that the Commissioner withheld $1,056.75 (Dkt. 21-7 at 2), $637.50 (Dkt. 21-8 at 2), $1,056.75 (Dkt. 21-9 at 2), and $920.75 (Dkt. 21-10 at 2) from Plaintiff’s children’s past-due benefits to pay for attorneys’ fees. On August 13, 2024, Plaintiff moved pursuant to 42 U.S.C. § 406(b) seeking

$31,551.25 in attorneys’ fees. (Dkt. 21). In her motion, Plaintiff’s counsel indicates that her firm was awarded the sum of $6,647.86 under the EAJA, which she will refund to Plaintiff. (Dkt. 21-1 at 2-3). The Commissioner filed a response on September 3, 2024. (Dkt. 25). DISCUSSION

I. Timeliness of the Motion Generally, a fee application under § 406(b) must be filed within 14 days after the entry of judgment. Fed. R. Civ. P. 54(d)(2)(B)(1). Rule 54(a)(2)(B) as applied to § 406(b) motions for attorneys’ fees, requires that a party moving for attorneys’ fees file the motion within 14 days of notice of a benefits award. Sinkler v. Berryhill, 932 F.3d 83, 88 (2d Cir. 2019). A presumption applies that a notice is received “three days after mailing.” Id. at

89 n.5; see also Fed. R. Civ. P. 6(d). Moreover, it has been determined that the 14-day limitation period is subject to equitable tolling “until the claimant receives notice of the amount of a benefits award. That is because the benefits award amount is necessary to identify the maximum attorney’s fee that may be awarded under § 406(b).” Sinkler, 932 F.3d at 85. Here, the Commissioner issued the Notice of Award related to Plaintiff’s DIB claim

on July 22, 2024, and issued the four Notices of Award related to Plaintiff’s child auxiliary claims on July 24, 2024. (Dkt. 21-3; Dkt. 21-7; Dkt. 21-8; Dkt. 21-9; Dkt. 21-10). Because the timeliness of Plaintiff’s application should be assessed from July 24, 2024—the date of the Notices of Award related to Plaintiff’s child auxiliary claims—Plaintiff’s application should have been filed by August 12, 2024.1 See Georgette T. v. Comm’r of Soc. Sec., No.

1:20-CV-00846-EAW, 2024 WL 1192993, at *2 (W.D.N.Y. Mar. 20, 2024) (concluding that time period for filing § 406(b) motion tolled until notice regarding plaintiff’s child’s benefits claim was issued, because until then counsel could not determine the maximum attorneys’ fees available, and collecting cases reaching the same conclusion). Plaintiff filed the instant application one day late—on August 13, 2024. (Dkt. 21).

In her papers Plaintiff’s counsel acknowledges that the motion was untimely, explains the

1 The 17th day after July 24, 2024, fell on a Saturday, and thus Plaintiff’s application was due by Monday, August 12, 2024. late filing by a calendaring error, and requests the tolling of the filing deadline by one day. (Dkt. 21-2 at ¶ 12).

Under the circumstances, the Court finds excusable neglect and exercises its discretion to excuse Plaintiff’s delay in submitting the instant application. The Court finds that counsel appears to have acted in good faith and no party has suffered any prejudice by the short delay. See, e.g., Eddie Lee S. v. Comm’r of Soc. Sec., No. 18-CV-186(HKS), 2021 WL 5296907, at *2 (W.D.N.Y. Nov. 15, 2021) (plaintiff’s short 6-day delay excused); Lesterhuis v. Comm’r of Soc. Sec., 408 F. Supp. 3d 292, 295 (W.D.N.Y. 2019)

(nine-day delay excused); Tanner v. Comm’r of Soc. Sec., No. 5:15-CV-577(TJM/ATB), 2018 WL 6521585, at *3 (N.D.N.Y. Dec. 12, 2018) (19-day delay found to be brief and justified when it was not a bad-faith attempt to increase the recovered fees). Accordingly, excusable neglect justifies the late filing of Plaintiff’s application. II. The Reasonableness of the Requested Fee

Section 406(b) provides, in relevant part, as follows: Whenever a court renders a judgment favorable to a claimant under this subchapter who was represented before the court by an attorney, the court may determine and allow as part of its judgment a reasonable fee for such representation, not in excess of 25 percent of the total of the past-due benefits to which the claimant is entitled by reason of such judgment. . . .

42 U.S.C. § 406(b)(1)(A). In other words, § 406(b) allows a successful claimant’s attorney to seek court approval of his or her fees, not to exceed 25 percent of the total past-due benefits. Section 406(b) “calls for court review of [contingent-fee] arrangements as an independent check, to assure that they yield reasonable results in particular cases.” Gisbrecht v. Barnhart, 535 U.S. 789, 807 (2002). This review is subject to “one boundary line: Agreements are unenforceable to the extent that they provide for fees exceeding 25 percent of the past-due benefits.” Id. “Within the 25 percent boundary, . . . the attorney

for the successful claimant must show that the fee sought is reasonable for the services rendered.” Id. Accordingly, a fee is not automatically recoverable simply because it is equal to or less than 25 percent of the client’s total past-due benefits. “To the contrary, because section 406(b) requires an affirmative judicial finding that the fee allowed is ‘reasonable,’ the attorney bears the burden of persuasion that the statutory requirement has been satisfied.”

Id. at 807 n.17. As such, the Commissioner’s failure to oppose the motion is not dispositive. Mix v. Comm’r of Soc. Sec., No. 6:14-CV-06219 (MAT), 2017 WL 2222247, at *2 (W.D.N.Y. May 22, 2017). Several factors are relevant to the reasonableness analysis, including the following: (1) “whether the contingency percentage is within the 25% cap[;]” (2) “whether there has been fraud or overreaching in making the agreement[;]”

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