Junttila v. Commissioner of Social Security

CourtDistrict Court, S.D. Florida
DecidedJuly 23, 2025
Docket9:24-cv-81296
StatusUnknown

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

Bluebook
Junttila v. Commissioner of Social Security, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 24-CV-81296-ELFENBEIN

JOHAN PETER JUNTTILA,

Plaintiff,

v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant. ______________________________/

ORDER ON UNOPPOSED MOTION FOR ATTORNEY’S FEES UNDER THE EQUAL ACCESS TO JUSTICE ACT

THIS CAUSE is before the Court on Plaintiff Johan Peter Juntilla’s Unopposed Motion for Attorney’s Fees Under the Equal Access to Justice Act (the “Motion”). See ECF No. [26]. In the Motion, Plaintiff argues that Defendant’s position was not “substantially justified” and Plaintiff is the “prevailing party.” Id. at 1-3. Plaintiff asks the Court to award $9,550 in attorney’s fees and he notes Defendant does not object to the number of attorney hours, counsel’s hourly rate, or the total amount of attorney’s fees requested. Id. at 1. For the reasons explained below, the Motion, ECF No. [26], is GRANTED. I. LEGAL STANDARDS A. Entitlement to Costs and Fees Under the Equal Access to Justice Act Under the Equal Access to Justice Act, the Court may award “a judgment for costs” to “the prevailing party in any civil action brought” against “any agency or any official of the United States acting in his or her official capacity.” See 28 U.S.C. § 2412(a)(1). The Court may also “award reasonable fees and expenses of attorneys, in addition to the costs which may be awarded pursuant to subsection (a), to the prevailing party in any civil action brought” against “any agency or any official of the United States acting in his or her official capacity.” See id. § 2412(b); Pub. L. No. 96-481 §§ 201, 204, 94 Stat. 2321 (1980). In fact, the authorizing statue provides that “a court shall award to a prevailing party other than the United States fees and other expenses, in

addition to any costs awarded pursuant to subsection (a), incurred by that party in any civil action (other than cases sounding in tort), including proceedings for judicial review of agency action, brought . . . against the United States in any court having jurisdiction of that action, unless the court finds that the position of the United States was substantially justified or that special circumstances make an award unjust.” See 28 U.S.C. § 2412(d)(1)(A) (emphasis added). To receive costs and fees, a party “shall, within thirty days of final judgment in the action, submit to the court an application for fees and other expenses which shows that the party is a prevailing party and is eligible to receive an award under this subsection, and the amount sought, including an itemized statement from any attorney or expert witness representing or appearing in behalf of the party stating the actual time expended and the rate at which fees and other expenses

were computed. The party shall also allege that the position of the United States was not substantially justified.” See id. § 2412(d)(1)(B). A party is “prevailing” in a Social Security appeal if he wins “a remand order pursuant to sentence four of [42 U.S.C.] § 405(g).” See Shalala v. Schaefer, 509 U.S. 292, 300 (1993). A party is “eligible to receive an award,” if his “net worth” does “not exceed $2,000,000 at the time the civil action was filed.” See 28 U.S.C. § 2412(d)(2)(B). And the “‘position of the United States’ means, in addition to the position taken by the United States in the civil action, the action or failure to act by the agency upon which the civil action is based.” See id. § 2412(d)(2)(D). “Whether or not the position of the United States was substantially justified shall be determined on the basis of the record (including the record with respect to the action or failure to act by the agency upon which the civil action is based) which is made in the civil action for which fees and other expenses are sought.” See id. § 2412(d)(1)(B). The Supreme Court has held that Equal Access to Justice attorney’s fee awards are payable

not to the lawyer but “to the litigant,” which means that any such award is subject to “a federal administrative offset if the litigant has outstanding federal debts.” See Astrue v. Ratliff, 560 U.S. 586, 593, 596 (2010); Rodriguez, 2023 WL 3852275, at *4. The litigant may, however, assign his “rights in the fees award to the attorney,” see Astrue, 560 U.S. at 597, as long as the assignment either complies with the Anti-Assignment Act, 31 U.S.C. § 3727(b), see Rodriguez, 2023 WL 3852275, at *4, or the government has waived the Anti-Assignment Act’s requirements, see Arthur Pew Const. Co. v. Lipscomb, 965 F.2d 1559, 1576 (11th Cir. 1992). If the litigant “does not owe a debt to the government and assigns the right to receive the fees to the attorney,” the government will pay the award to the attorney directly. See Astrue, 560 U.S. at 597 (quotation marks omitted). B. Calculating Attorney’s Fee Awards Generally

To calculate attorney’s fee awards, courts generally use the “lodestar” method. See Norman v. Hous. Auth. of City of Montgomery, 836 F.2d 1292, 1299 (11th Cir. 1988); Inj. Treatment Ctr., 2022 WL 17325834, at *2. “The most useful starting point for determining the amount of a reasonable fee” using the lodestar method “is the number of hours reasonably expended on the litigation multiplied by a reasonable hourly rate. This calculation provides an objective basis on which to make an initial estimate of the value of a lawyer’s services.” See Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); ACLU of Ga. v. Barnes, 168 F.3d 423, 427 (11th Cir. 1999) (noting that the lodestar is “properly calculated by multiplying the number of hours reasonably expended on the litigation times a reasonable hourly rate” (quoting Blum v. Stenson, 465 U.S. 886, 888 (1984))). “[T]here is a ‘strong presumption’ that the lodestar is the reasonable sum the attorneys deserve.” See Bivins v. Wrap It Up, Inc., 548 F.3d 1348, 1350 (11th Cir. 2008) (quoting Pennsylvania v. Del. Valley Citizens’ Council for Clean Air, 478 U.S. 546, 565–66 (1986)).

“The first step in the computation of the lodestar is determining the reasonable hourly rate.” Loranger v. Stierheim, 10 F.3d 776, 781 (11th Cir. 1994). “A reasonable hourly rate is the prevailing market rate in the relevant legal community for similar services by lawyers of reasonably comparable skills, experience, and reputation.” Id. (quoting Norman, 836 F.2d at 1299). “The general rule is that the relevant market for purposes of determining the reasonable hourly rate for an attorney’s services is the place where the case is filed.” Barnes, 168 F.3d at 437.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

ACLU of Georgia v. Miller
168 F.3d 423 (Eleventh Circuit, 1999)
Bivins v. Wrap It Up, Inc.
548 F.3d 1348 (Eleventh Circuit, 2008)
Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Blum v. Stenson
465 U.S. 886 (Supreme Court, 1984)
Shalala v. Schaefer
509 U.S. 292 (Supreme Court, 1993)
Astrue v. Ratliff
560 U.S. 586 (Supreme Court, 2010)
Fox v. Vice
131 S. Ct. 2205 (Supreme Court, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Junttila v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/junttila-v-commissioner-of-social-security-flsd-2025.