Lieu v. Kijakazi

CourtDistrict Court, S.D. California
DecidedApril 28, 2025
Docket3:23-cv-00640
StatusUnknown

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

Bluebook
Lieu v. Kijakazi, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 RICHARD T. L. Case No.: 23-cv-640-DDL 12 Plaintiff, ORDER GRANTING IN PART 13 v. AND DENYING IN PART PLAINTIFF’S MOTION FOR 14 LELAND DUDEK, ACTING AWARD OF ATTORNEY’S FEES 15 COMMISSIONER OF SOCIAL PURSUANT TO THE EQUAL ACCESS TO JUSTICE ACT SECURITY,1 16 Defendant. [Dkt. No. 28] 17 18 19 Pursuant to the Equal Access to Justice Act (the “Act” or “EAJA”), Plaintiff 20 Richard T. L. (“Plaintiff”) moves for an award of $47,728.44 in fees and $495.00 in 21 costs incurred by his counsel in connection with his appeal from an adverse 22 decision of the Commissioner (the “Motion”). Dkt. No. 28. For the reasons set 23 forth below, the Motion is GRANTED IN PART and DENIED IN PART. 24 / / / 25 / / / 26 27 1 Leland Dudek is automatically substituted for Kilolo Kijakazi pursuant to 28 1 I. 2 BACKGROUND 3 Plaintiff appealed the denial of his claim for Disability Insurance and 4 Supplemental Security Income benefits under Titles II and XVI of the Social 5 Security Act. Dkt. No. 1 at 1. On September 19, 2024, the Court affirmed the ALJ’s 6 denial of disability insurance benefits under Title II but remanded Plaintiff’s claim 7 for supplemental security income under Title XVI for further administrative 8 proceedings. Dkt. No. 26 at 26.2 The Court found the ALJ erred in failing to 9 consider medical evidence predating November 21, 2019 when adjudicating the 10 Title XVI claim. Id. at 10. 11 Plaintiff now moves for an award of his attorney’s fees and costs. Plaintiff 12 asserts he is the prevailing party within the meaning of the Act and requests that 13 his counsel be compensated for 162 hours expended on the litigation (including 14 the request for fees now before the Court) at an enhanced rate of $ 294.62 per hour. 15 See generally Dkt. No. 28; Dkt. No. 31. Plaintiff further requests any fee award be 16 paid directly to his counsel. Dkt. No. 28 at 33. 17 The Commissioner opposes Plaintiff’s motion, asserting Plaintiff does not 18 qualify for an award under the EAJA, or, in the alternative, the award should be 19 subject to a reduction. See generally Dkt. No. 30. The Commissioner further asserts 20 any award should be paid to Plaintiff and not to Plaintiff’s counsel. Id. at 24. 21 II. 22 LEGAL STANDARDS 23 The EAJA provides for the recovery of fees and costs by the prevailing party 24 in litigation against the United States or its agencies. See generally 28 U.S.C. § 2412. 25 As is relevant to the Motion, the Act provides that upon timely application: 26

27 28 1 . . . a court may award reasonable fees and expenses of attorneys, in addition to the costs which may be awarded pursuant to subsection 2 (a), to the prevailing party in any civil action brought by or against the 3 United States or any agency or any official of the United States acting 4 in his or her official capacity in any court having jurisdiction of such action. The United States shall be liable for such fees and expenses to 5 the same extent that any other party would be liable under the 6 common law or under the terms of any statute which specifically 7 provides for such an award. 8 9 Id., § 2412(b). Any application for attorney’s fees must be supported by “an 10 itemized statement from any attorney . . . representing or appearing in [sic] behalf 11 of the party stating the actual time expended and the rate at which fees and other 12 expenses were computed.” Id., § 2412(d)(1)(B). Fees and expenses are not 13 recoverable by a party whose net worth exceeds $2,000,000. Id., § 2412(d)(2). 14 The Court may in its discretion decline to award fees where it finds “that the 15 position of the United States was substantially justified or that special 16 circumstances make an award unjust.” Id., § 2412(d)(1)(A). The Court may 17 likewise reduce or deny any award to a party whose conduct “unduly and 18 unreasonably” delayed the proceedings. Id., § 2412(d)(1)(C). The Court’s fee 19 award should be “adequate to attract competent counsel, but . . . [should] not 20 produce windfalls to attorneys.” Hensley v. Eckerhart, 461 U.S. 424, 430 n.4 (1983).3 21 / / / 22 / / / 23 / / / 24 / / / 25 26 3 Unless otherwise noted, all citations, subsequent history, and parallel 27 reporter citations are omitted, and in direct quotes, all internal quotation marks, 28 1 III. 2 DISCUSSION 3 A. Plaintiff’s Eligibility for Fees 4 1. Plaintiff Is the Prevailing Party on the Title XVI Claim 5 The Ninth Circuit has long held that “litigants who achieve relief other than 6 a judgment on the merits” may nevertheless be considered prevailing parties for 7 purposes of the Act. Li v. Keisler, 505 F.3d 913, 917 (9th Cir. 2007) (citing Carbonell 8 v. INS, 429 F.3d 894, 899 (9th Cir. 2005) and Rueda-Menicucci v. INS, 132 F.3d 493, 9 495 (9th Cir. 1997)). Accordingly, the Court finds that although it did not afford 10 Plaintiff the full extent of relief requested in the complaint, Plaintiff is nevertheless 11 the prevailing party for purposes of the Act with respect to his Title XVI claim.4,5 12 The Commissioner does not appear to dispute this point. See generally Dkt. No. 30. 13 2. The Commissioner’s Position Was Not Substantially Justified 14 The Court next considers whether the Government’s position in the 15 litigation was “substantially justified.” 28 U.S.C. § 2412(d)(1)(A). “Substantial 16 justification” in this context means that the government’s position had a 17 reasonable basis in law and fact. Pierce v. Underwood, 487 U.S. 552, 565 (1988). It is 18

19 20 4 Plaintiff sought reversal of the Commissioner’s decision, a finding that Plaintiff is disabled and a remand for an award of retroactive and prospective 21 benefits, in addition to his reasonable attorney’s fees. See Dkt. No. 1 at 7. 22 5 Plaintiff did not prevail on his Title II claim, as to which the Court found the 23 ALJ’s disability determination was legally sound and supported by substantial 24 evidence. See Dkt. No. 26 at 1, 26. Although prevailing party status requires an 25 evaluation of the “degree of success obtained,” see Comm’r, INS v. Jean, 496 U.S. 154, 160 (1990) (hereinafter “Jean”), the Court determines it Plaintiff’s limited 26 success is best addressed in the context of counsel’s requested fee, as more fully 27 explained below. See id. at 162 (“the EAJA . . . favors treating a case as an inclusive 28 1 the government’s burden to establish substantial justification. Gutierrez v. Barnhart, 2 274 F.3d 1255, 1258 (9th Cir. 2001). The “position of the United States” includes 3 the decisions made at the administrative level, as well as the government’s 4 decision to defend the federal action. See Li, 505 F.3d at 918. 5 Here, Plaintiff prevailed on his Title XVI claim on the narrow issue of the 6 ALJ’s decision to preclude evidence prior to November 2019. Dkt. No. 28-1 at 13. 7 The Court agrees “Plaintiff is not entitled to EAJA fees simply because he 8 prevailed in Court.” Dkt. No. 30 at 7. Nevertheless, the Court’s finding that the 9 ALJ erroneously excluded this evidence “without explanation” or “legal 10 justification” indicates the ALJ’s position was not substantially justified. See Dkt. 11 No. 26 at 10-11.

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Pierce v. Underwood
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Moreno v. City of Sacramento
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Nadarajah v. Holder
569 F.3d 906 (Ninth Circuit, 2009)
Jianping Li v. Keisler
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Karen Garrison v. Carolyn W. Colvin
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239 F.3d 1140 (Ninth Circuit, 2001)
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Lieu v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lieu-v-kijakazi-casd-2025.