Harris v. Social Security Administration

CourtDistrict Court, D. New Mexico
DecidedMarch 24, 2025
Docket1:21-cv-00461
StatusUnknown

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

Bluebook
Harris v. Social Security Administration, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

GABRIELLE H., Plaintiff,

vs.

Case No.: 1:21-cv-00461-KRS LELAND DUDEK, Acting Commissioner of Social Security Administration, Defendant.

ORDER GRANTING IN PART PLAINTIFF’S MOTION FOR ATTORNEY FEES PURSUANT TO 42 U.S.C. § 406(b)

THIS MATTER is before the Court on Plaintiff’s Motion for Attorney Fees Pursuant to 42 U.S.C. § 406(b) (“Motion”), (Doc. 39), filed on March 10, 2025. (Doc. 39). Plaintiff’s counsel, Benjamin E. Decker (“Mr. Decker” or “Plaintiff’s counsel”), conferred with counsel for the Social Security Administration in accordance with D.N.M.LR-Civ. 7.1(a), and Defendant “takes no position on the relief sought by this Motion.” (Doc. 39 at 6). In the Motion, Plaintiff’s counsel petitions the Court for an order authorizing attorney fees in the amount of $18,453.50 for legal services rendered before this Court. (Doc. 39 at 6). The Court having reviewed the Motion and the relevant law, finds the Motion shall be GRANTED IN PART. I. PROCEDURAL BACKGROUND Plaintiff instituted an action in this Court seeking judicial review of Defendant’s denial of her application for Social Security disability benefits. The Court reversed the decision of the Commissioner and remanded for a new hearing. Subsequently, the Court awarded Plaintiff attorney fees in the amount of $4,817.80 pursuant to the Equal Access to Justice Act (“EAJA”), 28 U.S.C. § 2412. (See Doc. 37). On February 8, 2024, upon remand, the Social Security Administration determined Plaintiff was disabled, entered a fully favorable decision, and awarded her past-due benefits of $73,814.00. (See Doc. 39 at 6; Doc. 39-2 at 4). Plaintiff was further notified that the Social Security Administration withheld $18,453.50 from her total benefit payment pending an award of attorney fees pursuant to 42 U.S.C. § 406(b), which constitutes twenty-five percent of total backpay benefits. (See Doc. 39 at 6; Doc. 39-2 at 4). Plaintiff’s counsel now seeks an award of $18,453.50, approximately twenty-five percent of the total past-due benefits awarded to Plaintiff, pursuant to the contingency fee agreement Plaintiff entered into with Mr. Decker. (Doc. 39 at 6; Doc. 39-3 at 1). In the Motion, Plaintiff’s

counsel explains that he will refund to Plaintiff $4,817.80 in EAJA fees previously awarded by the Court, which would result in an hourly rate of $835.00.1 See (Doc. 39 at 6). As stated above, Defendant takes no position on the Motion. (Id.) II. ANALYSIS A court may award fees under Section 406(b) when, as here, "the court remands . . . a case for further proceedings and the Commissioner ultimately determines that the claimant is entitled to an award of past-due benefits." McGraw v. Barnhart, 450 F.3d 493, 496 (10th Cir. 2006). "The tenor of § 406(b) is permissive rather than mandatory." Whitehead v. Richardson, 446 F.2d 126, 128 (6th Cir. 1971). "It says that the court may make such an award, not that such an award shall be made." Id. Traditionally, an award of attorney fees is a matter within the sound discretion of the

1 Notably, Plaintiff did not include Mr. Decker’s hourly rate in the Motion. The Court, sua sponte, determines that the Mr. Decker’s requested hourly rate is based on a Section 406(b) award in the amount of $18,453.50 with 22.1 hours of work on this matter. (Doc. 39 at 6). $18,453.50 divided by 22.1 hours is $835 per hour. court. Id. Section 406(b) does impose some guidelines, however, permitting only "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." § 406(b)(1)(A). Unlike EAJA fees, which are paid in addition to past-due benefits, Section 406(b) fees are paid out of past-due benefits. Wrenn ex rel. Wrenn v. Astrue, 525 F.3d 931, 933–34 (10th Cir. 2008). If fees are awarded under both EAJA and Section 406(b), the attorney must refund the lesser award to the claimant. Id. at 934. The reasonableness of Section 406(b) fees is determined largely by "the character of the representation and the results the representative achieved." Id. at 808 (citations omitted). Factors relevant to the reasonableness of the fee request include: (1) whether the attorney's representation

was substandard; (2) whether the attorney was responsible for any delay in the resolution of the case; and (3) whether the contingency fee is disproportionally large in comparison to the amount of time spent on the case. See id. Ultimately, Plaintiff's attorney has the burden of showing that the fee sought is reasonable. Id. at 807 ("Within the 25 percent boundary, . . . the attorney for the successful claimant must show that the fee sought is reasonable for the services rendered."). In addition to a record of the number of hours spent representing a claimant in federal court, a court may also require an attorney to submit a statement of his normal hourly billing rate for non- contingency fee cases. Id. In the context of a Section 406(b) fee request, the court's first inquiry is whether the fee agreement between the claimant and her attorney meets Section 406(b) guidelines. Although

Section 406(b) does not prohibit contingency fee agreements, it does render them unenforceable to the extent that they provide fees in excess of 25 percent of the past-due benefits. Id. at 807. Here, the contingency agreement between Plaintiff and her attorney provided that if Plaintiff was awarded benefits by the Social Security Administration following a remand that Mr. Decker would be entitled to “twenty-five percent (25%) of all the past-due benefits that are awarded to” Plaintiff. (Doc. 39-3 at 1). Thus, on its face, Plaintiff's fee agreement meets Section 406(b)(1)'s guideline of not exceeding 25 percent of the past-due benefits. Still, Section 406(b) requires the Court to act as "an independent check" to ensure that fees are reasonable. Gisbrecht, 535 U.S. at 807 n.17. Applying the factors outlined in Gisbrecht, the Court finds that Mr. Decker achieved a fully favorable result for Plaintiff in this case, resulting in a significant past-due payment as well as a continuing monthly award. Moreover, the Court cannot say that Mr. Decker was responsible for any delay in the resolution of this case. The instant motion

was filed less than a month after Plaintiff received notice of entitlement to past-due benefits. (Compare Doc. 32, with Docs. 32-1, 32-2). An attorney's experience is another relevant factor when considering a Section 406(b) fee request. See Gordon v. Astrue, 361 F. App'x 933, at 2–3 (10th Cir. 2010) (noting that in addition to the Gisbrecht factors, the trial court also considered the factors established by the Seventh Circuit in McGuire v. Sullivan, 873 F.2d 974, 983 (7th Cir. 1989), which include the attorney's experience). Mr. Decker has been practicing law for 17 years. (Doc. 39 at 2). He is a member of the National Organization of Social Security Representatives, trains other lawyers in Social Security law, and regularly practices in federal court. (Id. at 3). In addition, the Court finds that Mr. Decker’s representation of Plaintiff in this case was more than adequate. Mr.

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Related

McGraw v. Barnhart
450 F.3d 493 (Tenth Circuit, 2006)
Wrenn Ex Rel. Wrenn v. Astrue
525 F.3d 931 (Tenth Circuit, 2008)
Gordon v. Astrue
361 F. App'x 933 (Tenth Circuit, 2010)
Whitehead v. Richardson
446 F.2d 126 (Sixth Circuit, 1971)
McGuire v. Sullivan
873 F.2d 974 (Seventh Circuit, 1989)

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Bluebook (online)
Harris v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-social-security-administration-nmd-2025.