Heim v. Commissioner of Social Security

CourtDistrict Court, W.D. New York
DecidedDecember 20, 2024
Docket1:18-cv-00714
StatusUnknown

This text of Heim v. Commissioner of Social Security (Heim 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
Heim v. Commissioner of Social Security, (W.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK _______________________________________

BRANDY H.,1 DECISION & ORDER Plaintiff, 18-CV-0714MWP v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant. _______________________________________

PRELIMINARY STATEMENT On June 26, 2018, plaintiff Brandy H. (“plaintiff”) commenced this action seeking judicial review of a final decision of the Commissioner of Social Security (the “Commissioner”) denying her application for Supplemental Security Income (“SSI”). (Docket # 1). Pursuant to the Standing Order of the United States District Court for the Western District of New York regarding Social Security cases dated June 29, 2018, this case has been reassigned to, and the parties have consented to the disposition of this case by, the undersigned. (Docket # 15). On March 27, 2020, this Court entered a judgment reversing the Commissioner’s denial of SSI and remanding the case to the Commissioner pursuant to 42 U.S.C. § 405(g), sentence four, for further administrative proceedings. (Docket # 16). Judgment was entered remanding the case on March 30, 2020. (Docket # 17).

1 Pursuant to the November 18, 2020 Standing Order of the United States District Court for the Western District of New York regarding identification of non-governmental parties in social security opinions, the plaintiff in this matter will be identified and referenced solely by first name and last initial. Following the entry of the judgment, plaintiff’s counsel, the Law Offices of Kenneth R. Hiller, PLLC (“Hiller”), filed the pending motion for an award of attorney’s fees pursuant to the Equal Access to Justice Act (“EAJA”), 28 U.S.C. § 2412, in the amount of $8909.44.2 (Docket # 24 at 6). The Commissioner opposes the motion, arguing plaintiff is not

entitled to fees because the Commissioner’s position, while not persuasive, was substantially justified both at the administrative level and before this Court. (Docket # 20). In the alternative, the Commissioner maintains plaintiff’s EAJA fee request should be denied because an award would be unjust under the special circumstances of this case. (Id. at 6-8). For the reasons discussed below, plaintiff’s motion for attorney fees under the EAJA is granted and plaintiff is awarded $8,909.44 in fees.

ANALYSIS The EAJA authorizes an award of “reasonable fees and expenses of attorneys . . . to the prevailing party in any civil action brought by or against the United States or any agency

or any official of the United States acting in his or her official capacity.” 28 U.S.C. § 2412(b). An EAJA fee award is appropriate “unless the court finds that the position of the United States was substantially justified or that special circumstances make an award unjust.” 28 U.S.C. § 2412(d)(1)(A). If the Court finds that the position of the United States was not substantially justified, and that there were no special circumstances to make an award unjust, then the “Court must determine if the hours expended and the rates charged are reasonable, and the fee applicant

2 Initially, plaintiff sought fees in the amount of $7,742.33. (Docket # 18-1 at 5). In its reply submission, plaintiff requested additional fees for time expended in connection with its reply to the Commissioner’s opposition to the EAJA fee application. (Docket # 24 at 6). has the burden to establish the reasonableness of both.” Hogan v. Astrue, 539 F. Supp. 2d 680, 682 (W.D.N.Y. 2008) (citing Hensley v. Eckerhart, 461 U.S. 424, 433 (1983)). I. Substantially Justified or Special Circumstances The Commissioner bears the burden of showing that its position was

“substantially justified,” which the Supreme Court has construed to mean “justified to a degree that could satisfy a reasonable person.” Ericksson v. Comm’r of Soc. Sec., 557 F.3d 79, 81 (2d Cir. 2009) (quoting Pierce v. Underwood, 487 U.S. 552, 565 (1988)). To accomplish this, the Commissioner must make a “strong showing that its position in the underlying civil action . . . was reasonable.” Leon ex rel. J.E.V. v. Colvin, 2018 WL 4404577, *2 (W.D.N.Y. 2018). In support of its contention that its position to oppose remand was substantially justified, the Commissioner simply reiterates the same arguments it presented to this Court in opposition to the plaintiff’s appeal. (See generally Docket # 20 at 3-6). I find such arguments insufficient to demonstrate the requisite “strong showing” necessary to establish that the Commissioner’s underlying position was substantially justified. See Padula v. Colvin, 602 F.

App’x 25, 27 (2d Cir. 2015) (summary order) (“the Commissioner continues to urge a view of the evidence suggesting that it should have prevailed on the merits of the prior appeal, but this reprise of arguments we previously found unavailing is insufficient on its own to show that her position had a reasonable basis in both law and fact”) (internal quotations and alterations omitted). Accordingly, I conclude that the Commissioner has failed to meet its burden to demonstrate substantial justification. I reach the same conclusion regarding the Commissioner’s contention that special circumstances exist which would make an award of attorney’s fees in this case unjust. In “rare situations,” equitable considerations may make an EAJA fee award unjust. Mills v. Colvin, 2013 WL 1499606, *3 (N.D.N.Y. 2013). The “EAJA’s ‘special circumstances’ exception is a ‘safety valve’ that gives ‘the court discretion to deny awards where equitable considerations dictate an award should not be made.’” Vincent v. Comm’r of Soc. Sec., 651 F.3d 299, 303 (2d Cir. 2011) (quoting Scarborough v. Principi, 541 U.S. 401, 422-23 (2004)).

The crux of the Commissioner’s position is that this Court’s decision to remand relied upon two recent Second Circuit cases, Estrella v. Berryhill, 925 F.3d 90 (2d Cir. 2019) and Ferraro v. Saul, 806 F. App’x 13 (2d Cir. 2020), which were issued following the briefing on the cross-motions for judgment on the pleadings filed in this case. (Docket # 20 at 7). According to the Commissioner, plaintiff failed to apprise the Court of this controlling authority and “does not deserve attorney[s’] fees when she left it to the Commissioner and the Court to discover new Second Circuit authority.” (Docket # 20 at 7). I disagree. Although this Court cited the most recent Second Circuit authority in its decision, the holdings in those cases were not the primary basis for remand. In Estrella, the Second Circuit held that the ALJ commits a procedural error when it fails to explicitly discuss the

Burgess factors. Estrella v. Berryhill, 925 F.3d at 95-96. Similarly, in Ferraro, the Second Circuit held that the ALJ failed to correctly apply the treating physician rule, in part, because he failed to explicitly consider the nature and extent of the treating history provided by the physician. Ferraro v. Saul, 806 F. App’x at 15.

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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)
Scarborough v. Principi
541 U.S. 401 (Supreme Court, 2004)
Astrue v. Ratliff
560 U.S. 586 (Supreme Court, 2010)
Ericksson v. Commissioner of Social Security
557 F.3d 79 (Second Circuit, 2009)
Hogan v. Astrue
539 F. Supp. 2d 680 (W.D. New York, 2008)
Colegrove v. Barnhart
435 F. Supp. 2d 218 (W.D. New York, 2006)
Vincent v. Commissioner of Social Security
651 F.3d 299 (Second Circuit, 2011)
Padula v. Colvin
602 F. App'x 25 (Second Circuit, 2015)
Estrella v. Berryhill
925 F.3d 90 (Second Circuit, 2019)

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Heim v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heim-v-commissioner-of-social-security-nywd-2024.