Gibbons v. Commissioner of Social Security

CourtDistrict Court, W.D. New York
DecidedApril 28, 2025
Docket1:21-cv-00658
StatusUnknown

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

Bluebook
Gibbons v. Commissioner of Social Security, (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK ___________________________________

PATRICIA G.,

Plaintiff, DECISION AND ORDER v. 1:21-CV-00658-EAW COMMISSIONER OF SOCIAL SECURITY,

Defendant. ____________________________________

INTRODUCTION Plaintiff Patricia G. (“Plaintiff”) seeks attorneys’ fees in the amount of $36,593.00 pursuant to 42 U.S.C. § 406(b). (Dkt. 34). The Commissioner of Social Security (“the Commissioner”) neither supports nor opposes Plaintiff’s fee request. (Dkt. 37 at 1). For the reasons below, the Court grants Plaintiff’s motion. BACKGROUND On May 21, 2021, Plaintiff filed this action, seeking review of the Commissioner’s final decision denying her application for Disability Insurance Benefits (“DIB”). (Dkt. 1). Plaintiff moved for judgment on the pleadings on February 16, 2022. (Dkt. 12). The Commissioner responded on April 15, 2022. (Dkt. 13). On September 7, 2023, Plaintiff filed a motion seeking remand of the matter for further proceedings. (Dkt. 23). The Commissioner responded on October 2, 2024. (Dkt. 26). On March 20, 2024, the Hon. Donald D. Bush issued a Decision and Order granting Plaintiff’s motion for judgment on the pleadings, denying as moot Plaintiff’s motion for

remand, reversing the Commissioner’s final decision, and remanding the matter for further proceedings. (Dkt. 30). By Stipulated Order filed on May 3, 2024, Judge Bush approved payment of $10,000.00 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 $402.00 in costs. (Dkt. 33).

On November 23, 2024, the Commissioner issued a Notice of Change in Benefits in connection with Plaintiff’s claim, which stated that the Commissioner withheld $36,593.00 from Plaintiff’s past-due benefits to pay for Plaintiff’s attorneys’ fees. (Dkt. 34-4 at 3). On January 7, 2025, Plaintiff moved under 42 U.S.C. § 406(b) seeking $36,593.00

in attorneys’ fees. (Dkt. 34). In her motion, Plaintiff’s counsel indicates that her firm received the sum of $10,000.00 under the EAJA, which she will refund to Plaintiff. (Dkt. 34-1 at 5). The Commissioner filed a response on February 11, 2025. (Dkt. 31).1 On April 9, 2025, the case was reassigned to the undersigned. (Dkt. 38).

1 The Commissioner seeks an extension of time to file its response (Dkt. 36), which is granted. 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 also applies that a notice is received “three days after mailing.” Id. at 89 n.5; see also Fed. R. Civ. P. 6(d).

Here, the Commissioner issued the Notice of Change in Benefits associated with Plaintiff’s claim on November 23, 2024. (Dkt. 34-4). Considering the requirements of Fed. R. Civ. P. 6(d) and 54(d)(2)(B), Plaintiff’s motion for attorneys’ fees was due on December 10, 2024. However, Plaintiff’s counsel filed Plaintiff’s application twenty-eight days later on January 7, 2025. (Dkt. 34). Plaintiff’s counsel explains that her office did

not receive the Notice of Change in Benefits until December 24, 2024, when Plaintiff’s former counsel, Lewis Schwartz, Esq., informed her of the existence of the Notice of Change in Benefits and provided her office with its copy. (Dkt. 34-1 at 2, 4; Dkt. 34-4 at 1). Plaintiff’s counsel filed the instant application fourteen days later on January 7, 2025. (Dkt. 34).

Under the circumstances of this case, the Court finds Plaintiff’s application timely because Plaintiff’s counsel filed it fourteen days after she first learned of the existence of the Notice of Change in Benefits from Plaintiff’s former counsel. See Sinkler v. Berryhill, 932 F.3d 83, 88 (2d Cir. 2019) (the fourteen period runs from when “counsel receives notice of the benefits award—and, therefore, the maximum attorney’s fees that may be claimed”). Accordingly, Plaintiff’s application is timely.

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. 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. Thus, 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[;]” and (3) “whether the requested amount is so large as to be a windfall to the attorney.” Wells v. Sullivan, 907 F.2d 367, 372 (2d Cir. 1990). Also relevant are the following: (1) “the character of the representation and the results the representative achieved[;]” (2) “the amount of time counsel spent on the case[;]” (3) whether “the attorney is responsible for delay[;]” and (4) “the lawyer’s normal hourly billing charge for noncontingent-fee cases.” Gisbrecht, 535

U.S. at 808.

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Related

Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Sinkler v. Berryhill
932 F.3d 83 (Second Circuit, 2019)
Fields v. Kijakazi
24 F.4th 845 (Second Circuit, 2022)

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Gibbons v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gibbons-v-commissioner-of-social-security-nywd-2025.