Looney v. Commissioner, Social Security Administration

CourtDistrict Court, D. Colorado
DecidedOctober 6, 2025
Docket1:22-cv-02343
StatusUnknown

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

Bluebook
Looney v. Commissioner, Social Security Administration, (D. Colo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Nina Y. Wang

Civil Action No. 22-cv-02343-NYW

J.T.L.,1

Plaintiff,

v.

FRANK BISIGNANO, Commissioner of the Social Security Administration,

Defendant.

ORDER

This matter is before the Court on Plaintiff’s Motion to Reopen Case Under Fed. R. Civ. P. 60(b) for an Award of Attorney Fees Pursuant to 42 USC 406(b) (the “Motion” or “Motion for Attorney’s Fees”). [Doc. 22]. Plaintiff’s counsel seeks $47,178.00 in attorney’s fees. [Id. at 1]. The Commissioner has filed a Response but takes no apparent position on the Motion, asking only that the Court “direct that Plaintiff’s counsel reimburse Plaintiff any fees he previously received under the Equal Access [to] Justice Act.” [Doc. 23 at 2]. Plaintiff J.T.L. (“Plaintiff” or “J.T.L.”) appealed to this Court for review of the Commissioner of Social Security’s final decision denying his application for Disability Insurance Benefits and Supplemental Security Income. See generally [Doc. 1].2 On

1 The Local Rules of Practice for this District state that “[a]n order resolving a social security appeal on the merits shall identify the plaintiff by initials only.” D.C.COLO.LAPR 5.2(b). Although the Court has already resolved J.T.L.’s appeal on the merits, the Court continues to use only Plaintiff’s initials to identify him. 2 Prior to initiating this case, Plaintiff filed an earlier appeal of the Commissioner’s denial of benefits on July 12, 2020. [Doc. 8-10 at 921–22]. The Honorable Robert E. Blackburn August 7, 2023, this Court entered a Memorandum Opinion and Order reversing and remanding the Commissioner’s decision. See [Doc. 18]. On November 3, 2024, the Social Security Administration determined that Plaintiff is entitled to monthly Social Security benefits, retroactive to September 2017. [Doc. 22-14 at 1].

A motion under § 406(b) must be filed within a “reasonable time of the Commissioner’s decision awarding benefits.” McGraw v. Barnhart, 450 F.3d 493, 505 (10th Cir. 2006). Here, Plaintiff’s Motion was filed on November 25, 2024, just weeks after the Social Security Administration’s Notice of Award. See [Doc. 22]. Accordingly, the Court finds the Motion is timely. See Shockley v. Saul, No. 19-cv-02584-REB, 2021 WL 9217693, at *1 n.2 (D. Colo. May 18, 2021) (“The filing of a motion within three months of the Notice is routinely found acceptable.”). Under § 406, an attorney’s fees award may not exceed 25% of the recovered past- due benefits and must also be “reasonable.” 42 U.S.C. § 406(b)(1)(A); see also Gisbrecht v. Barnhart, 535 U.S. 789, 807 (2002). A contingency fee agreement is the “the primary

means by which fees are set for successfully representing Social Security benefits claimants in court.” Gisbrecht, 535 U.S. at 807. “In determining whether a fee amount is reasonable, courts may consider factors such as the character of the representation, the results achieved, whether the benefits recovered are large in comparison to the amount of time spent on the case, and whether the plaintiff’s attorney is responsible for delay in

summarily reversed and remanded the decision after the Commissioner filed an unopposed motion to remand. [Id. at 919–20]; see also [J.T.L.] v. Commissioner, No. 20- cv-02029-REB (D. Colo.). Based on Judge Blackburn’s order, the Appeals Council remanded the case back to the ALJ. [Doc. 8-10 at 878]. The ALJ held another hearing on November 1, 2021, [Doc. 8-9 at 840], and issued another unfavorable decision on February 7, 2022. [Id. at 811–33]. This case arose out of Plaintiff’s appeal of that second unfavorable decision. the proceedings.” Trujillo v. Bisignano, No. 17-cv-01590-WJM, 2025 WL 2051737, at *1 (D. Colo. July 22, 2025) (citing Gisbrecht, 535 U.S. at 807–08). A district court has “considerable discretion” in determining the reasonableness of a fee awarded under § 406. Gordon v. Astrue, 361 F. App’x 933, 935 (10th Cir. 2010).

Plaintiff was awarded $188,712.00 in past due benefits, see [Doc. 22-14 at 3], though counsel represents that some portion of this amount has been withheld to pay Plaintiff’s child support debt, see [Doc. 22 at 3–4].3 Accordingly, the requested fee does not exceed 25% of the past-due benefits. But “[n]otwithstanding the terms of a contingent fee agreement, a court is obligated to consider whether the fee yielded by the agreement is reasonable.” Wallace v. Barnhart, No. 05-cv-01613-MSK, 2008 WL 4681926, at *2 (D. Colo. Oct. 21, 2008). Relevant here, “[i]f the benefits are large in comparison to the amount of time counsel spent on the case, a downward adjustment is . . . in order.” Gisbrecht, 535 U.S. at 808. Plaintiff’s counsel represents that he spent 14.9 total hours on the litigation in this

case, [Doc. 22-6 at 2–3], and 14.8 hours on the prior litigation, [Doc. 22-3 at 2–3]. An associate attorney at the firm represents that he spent 6.2 hours on this litigation, [Doc. 22-7 at 1–2], and spent 4.4 hours on the first litigation as a paralegal, [Doc. 22-4 at 1–2].4 This means that a total of 35.9 attorney hours were spent litigating Plaintiff’s case in federal court, and the requested fee award of $47,178.00 would amount to an hourly rate

3 The Motion does not make it entirely clear to the Court how much has been withheld to pay that debt. 4 Neither the Motion nor the associate’s affidavit informs the Court how many years of experience the associate attorney has. However, given that this associate worked as a paralegal in 2020 and 2021, the Court may infer that the associate had two or fewer years of experience when he performed his services as an attorney in 2022 and 2023. of $1,314.15. While the Court is not inclined to overly scrutinize a fee award agreed to by the Parties pursuant to a fee agreement, this hourly rate is well outside of the range that is widely considered reasonable in this District. See Bumgarner v. Saul, No. 19-cv- 02288-KLM, 2022 WL 1225309, at *2 (D. Colo. Apr. 26, 2022) (collecting cases).

Moreover, the Court also notes that many of the billed tasks are administrative in nature, and courts tend to be skeptical of awarding attorney’s fees—especially such high fees— for administrative work. See [Doc. 22-6 at 2 (billing for, inter alia, e-filing documents); Doc. 22-7 at 1 (billing 0.2 hours for reviewing, downloading, and saving the administrative record); Doc. 22-3 at 2 (billing for, inter alia, e-filing documents)]. If hours attributed to administrative tasks were disregarded, the effective hourly rate would be even higher. The Court also considers the result obtained. Gisbrecht, 535 U.S. at 807. In the first federal case, the Parties agreed to a stipulated remand. [Doc. 8-10 at 919–20]. And after this Court’s remand of the second federal case in 2023, the ALJ entered a “partially favorable” decision, finding that Plaintiff was not disabled as of his alleged onset date of

August 31, 2016, but was disabled as of March 14, 2017. [Doc. 22-9 at 1, 5–6]. The Court also observes that Plaintiff’s appeal spent a significant amount of time at the administrative level, which likely “contributed significantly to the unusually large award of back benefits.” Gordon, 361 F. App’x at 936 (quotation omitted); see, e.g., [Doc. 8-4 at 106 (the initial denial of benefits on October 6, 2017); Doc. 8-2 at 32 (the ALJ entering her original unfavorable decision on October 9, 2019); Doc. 8-10 at 919–20 (order remanding case dated March 19, 2021); Doc. 8-9 at 833 (the second unfavorable decision dated February 7, 2022)].

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Related

Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
McGraw v. Barnhart
450 F.3d 493 (Tenth Circuit, 2006)
Gordon v. Astrue
361 F. App'x 933 (Tenth Circuit, 2010)

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Looney v. Commissioner, Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/looney-v-commissioner-social-security-administration-cod-2025.