Greess v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedApril 27, 2022
Docket2:20-cv-00170
StatusUnknown

This text of Greess v. Commissioner of Social Security Administration (Greess 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
Greess v. Commissioner of Social Security Administration, (D. Ariz. 2022).

Opinion

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

9 David Matthew Greess, No. CV-20-00170-PHX-DJH

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Pending before the Court are Plaintiff’s Motion for Attorney Fees Under the Equal 16 Access to Justice Act (“EAJA”) (Doc. 24) and Plaintiff’s Motion for Attorney Fees under 17 42 U.S.C. § 406(b) (Doc. 31).1 Defendant filed a Response in Opposition to Plaintiff’s 18 Motion for Attorney Fees Under the EAJA (Doc. 26), and Plaintiff filed a Reply thereto 19 (Doc. 30). Defendant also filed a Response to Plaintiff’s Motion for Attorney Fees under 20 42 U.S.C. § 406(b) (Doc. 33), but Plaintiff has not filed any reply, and the time in which 21 to do so has expired. 22 I. Background 23 Plaintiff filed an application for Social Security Disability Insurance in December 24 2017, which was denied by an Administrative Law Judge and the Appeals Council. Upon 25 appeal to this Court, the parties jointly moved to remand the matter to the Commissioner 26 of Social Security under sentence four of 42 U.S.C. § 405(g). Plaintiff now seeks awards 27 of attorney fees. 28 11 Plaintiff filed separate memoranda in support (Docs. 25; 32). 1 II. 42 U.S.C. § 406(b) 2 The Court begins with Plaintiff’s Motion under 42 U.S.C. § 406(b), which provides 3 that the Court may award a reasonable attorney fee not in excess of 25% of past-due 4 benefits under Title II of the Social Security Act. In doing so, the Court must consider 5 whether the fee requested is within the statutory guidelines, is consistent with the fee 6 agreement, and is reasonable in light of the contingent-fee agreement. Gisbrecht v. 7 Barnhart, 535 U.S. 789 (2002). 8 Plaintiff seeks an award of $28,692.12. This amount is 25% of the total award 9 Plaintiff received, which Defendant withheld for this purpose. (Doc. 32-1 at 5). It is 10 consistent with the fee agreement, which Plaintiff provided. (Doc. 32-2 at 2). As to the 11 reasonableness of this amount in light of the agreement, Defendant takes no position. 12 (Doc. 33 at 5). The Court finds that this award is within the guidelines, consistent with the 13 agreement, and reasonable in light of the agreement. Therefore, the Court will grant the 14 Motion for Attorney Fees under 42 U.S.C. § 406(b). 15 III. EAJA 16 The Court turns to Plaintiff’s request for an award $10,004.63 under the EAJA. 17 (Doc. 30 at 12). 18 a. Legal Standard 19 In any action brought by or against the United States, except one sounding in tort, 20 the EAJA provides that “a court shall award to a prevailing party other than the United 21 States fees and other expenses . . . unless the court finds that the position of the United 22 States was substantially justified.” 28 U.S.C. § 2412(d)(1)(A); Tobeler v. Colvin, 749 F.3d 23 830, 832 (9th Cir. 2014). The fee applicant bears the burden of documenting the hours 24 spent litigating the case and must submit evidence to support those hours. Welch v. Metro. 25 Life Ins. Co., 480 F.3d 942, 948 (9th Cir. 2007). The fees and other expenses requested 26 must be reasonable. 28 U.S.C. § 2412(d)(2)(A). Courts have a “great deal of discretion in 27 determining the reasonableness of” attorney fee awards. Gates v. Deukmejian, 987 F.2d 28 1392, 1398 (9th Cir. 1992). 1 In the context of Social Security appeals, “attorneys’ fees are to be awarded to a 2 party winning a . . . remand unless the Commissioner shows that his position with respect 3 to the issue on which the district court based its remand was ‘substantially justified.’” 4 Lewis v. Barnhart, 281 F.3d 1081, 1083 (9th Cir. 2002) (quoting Flores v. Shalala, 49 F.3d 5 562, 568–69 (9th Cir. 1995)). Under Astrue v. Ratliff, 560 U.S. 586, 595–98 (2010), EAJA 6 fees awarded by the Court belong to Plaintiff and are subject to offset under the Treasury 7 Offset Program (31 U.S.C. § 3716(c)(3)(B)). When an attorney receives an award under 8 § 406(b) and the EAJA, the attorney must refund to the client the smaller of the awards. 9 Russell v. Sullivan, 930 F.2d 1443, 1446 (9th Cir. 1991). 10 b. Discussion 11 The Court finds, as Defendant concedes, that its position was not substantially 12 justified because the parties agreed to a voluntary remand. (Doc. 26 at 3 n.1). However, 13 Defendant argues that Plaintiff’s requested award of $10,004.63 is unreasonable and should 14 be reduced to $5,101.02. (Doc. 26 at 15). It particular, it argues the time it took Plaintiff’s 15 counsel to draft the Complaint (11.6 hours) and to edit the Opening Brief (14.5 hours) is 16 too long to be reasonable. It also argues that the time Plaintiff’s counsel spent reviewing 17 his own filings once they had been placed on the docket (1 hour) is unjustifiable. Finally, 18 Defendant requests that Plaintiff be prohibited from obtaining fees for the reply brief. 19 i. The Complaint 20 This matter’s Complaint is eleven pages long and contains detailed citations to the 21 law surrounding Social Security Appeals. Most of its pages contain footnotes that take up 22 half the page with block quotes from other cases. (See Doc. 1 at 5). The factual allegations 23 related to the present matter make up roughly half of the Complaint. Plaintiff’s counsel 24 represents that this document took 11.6 hours to review the administrative record, conduct 25 “extensive legal research,” draft, and edit the Complaint. (Doc. 25-2 at 2). 26 Defendant argues that the extensive legal research that went into the Complaint is 27 overkill because Plaintiff only needed a “simple complaint akin to . . . pro se complaints” 28 and not a legal brief. (Doc. 26 at 7). Accordingly, Defendants suggest a reasonable amount 1 of time to prepare the Complaint would have been two hours. (Id.) Plaintiff argues that 2 the time spent reviewing the 997-page-long administrative record takes up a great amount 3 of time and that his counsel’s practice of writing detailed, legally-intensive complaints is 4 intentionally designed to attempt to show a defendant why the case should be remanded 5 before the need for further briefing. (Doc. 30 at 7). 6 The Court finds it is certainly reasonable for counsel to review the administrative 7 record and prepare a well-written brief. However, the Court finds that fees incurred for 8 “extensive legal research” in the Complaint are unreasonable. Many of the Complaint’s 9 legal arguments are quite plainly boilerplate language that may be used in any number of 10 complaints.

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Related

Keller v. State Bar of California
496 U.S. 1 (Supreme Court, 1990)
Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Astrue v. Ratliff
560 U.S. 586 (Supreme Court, 2010)
United States v. Newman
49 F.3d 1 (First Circuit, 1995)
Welch v. Metropolitan Life Ins. Co.
480 F.3d 942 (Ninth Circuit, 2007)

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Greess v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/greess-v-commissioner-of-social-security-administration-azd-2022.