McCarthy v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedSeptember 4, 2025
Docket6:23-cv-00007
StatusUnknown

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

Bluebook
McCarthy v. Social Security Administration, (E.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

MICHAEL MCCARTHY, ) ) Plaintiff, ) ) v. ) Case No. 23-cv-007-DES ) FRANK BISIGNANO,1 ) Commissioner of Social Security, ) ) Defendant. )

OPINION AND ORDER AWARDING ATTORNEY FEES PURSUANT TO 42 U.S.C. § 406(b)

Before the Court is the Motion for Attorney Fees Under 42 U.S.C. § 406(b) filed by David F. Chermol, counsel for Plaintiff (“Counsel”). (Docket No. 27). The Commissioner neither supports nor objects to Counsel’s motion. (Docket No. 31). For the reasons set forth below, Counsel’s Motion for Attorney Fees Pursuant to 42 U.S.C. § 406(b) (Docket No. 27) is GRANTED, and $28,049.75 is awarded to Counsel pursuant to 42 U.S.C. § 406(b). I. Background Plaintiff appealed the Commissioner’s adverse decision denying his request for benefits. (Docket No. 2). The Court reversed the Commissioner’s decision and remanded the case for further proceedings in August 2023. (Docket Nos. 22, 23). As the prevailing party in such action, Plaintiff was awarded $7,000.00 in attorney fees pursuant to the Equal Access to Justice Act (“EAJA”). (Docket No. 26). On remand, the Commissioner found Plaintiff had been disabled since April 24, 2021, and Plaintiff was awarded past-due benefits in the amount of $112,199.00. (Docket No. 27-

1 Effective May 7, 2025, Frank Bisignano, Commissioner of Social Security, is substituted as the defendant in this action pursuant to Fed. R. Civ. P. 25(d). No further action is necessary to continue this suit by reason of 42 U.S.C. § 405(g). 1). The Commissioner withheld a total of $28,049.75 from Plaintiff’s award, which represents 25% of the total past-due benefits awarded, to pay attorney and/or representative fees. Id. at 4). Counsel requests a fee award of $28,049.75, or 25% of the total past-due benefits pursuant to both 42 U.S.C. § 406(b) and the terms of the contingency fee contract between Plaintiff and

Counsel. Plaintiff retained Counsel to appeal the Commissioner’s adverse decision denying benefits. As part of this engagement, Counsel entered into a contract for compensation with Plaintiff, providing for the payment of a fee equal to 25% of any past-due benefits ultimately awarded to Plaintiff. (Docket No. 27-2). Such contracts are recognized as valid under prevailing case authority. See Gisbrecht v. Barnhart, 535 U.S. 789, 807 (2002). As an initial matter, the Court finds that Counsel’s fee motion was timely filed. A request for fees pursuant to 42 U.S.C. § 406(b) must employ the relief provisions of Fed. R. Civ. P. 60(b)(6) to ensure timeliness. McGraw v. Barnhart, 450 F. 3d 493, 505 (10th Cir. 2006). Since Rule 60(b)(6) motions “must be made within a reasonable time,” Fed. R. Civ. P. 60(c)(1), a motion for attorney fees made pursuant to 42 U.S.C. § 406(b) must be filed “within a reasonable time of

the Commissioner’s decision awarding benefits.” McGraw, 450 F.3d at 505. In this District, “a reasonable time” means within thirty days of issuance of the notice of award unless there is good reason for a lengthier delay. See, e.g., Harbert v. Astrue, No. CIV-06-90-SPS, 2010 WL 3238958, at *1 n. 4 (E.D. Okla. Aug. 16, 2010) (“The Court notes here that while no explanation is needed for a Section 406(b)(1) motion filed within thirty days of issuance of the notice of a[ward], lengthier delays will henceforth be closely scrutinized for reasonableness, including the reasonableness of efforts made by appellate attorneys to obtain a copy of any notice of award issued to separate agency counsel.”). Here, the Commissioner issued the Notice of Award on

2 August 16, 2025 (Docket No. 27-1 at 1), and Counsel filed his motion for § 406(b) fees 10 days later, on August 26, 2025. (Docket No. 27). The Court thus concludes Counsel was diligent and timely in filing the request for § 406(b) fees. Regarding the amount of fees requested, “Congress prescribed specific limitations on the

amount of fees which may be awarded for representation of Social Security claims.” Wrenn ex rel. Wrenn v. Astrue, 525 F.3d 931, 932 (10th Cir. 2008). The amount awarded to an attorney for successfully prosecuting an appeal of a denial of Social Security benefits and obtaining benefits for a claimant may not exceed 25% of the claimant’s past-due benefits. Id. (citing 42 U.S.C. § 406(b)(1)(A)). Although § 406(b) does not displace contingency-fee arrangements for fees up to 25% of the past-due benefits, § 406(b) nonetheless calls for the Court to function as “an independent check” and review contingency-fee arrangements “to assure that they yield reasonable results in particular cases.” Gisbrecht, 535 U.S. at 807. Factors relevant to the reasonableness of the fee request include: (1) the character of the representation and the results achieved; (2) whether the attorney engaged in any dilatory conduct or provided substandard representation; and

(3) whether the contingency fee is disproportionately large in comparison to the amount of time spent on the case that a “windfall” to the attorney would result. Id. at 808. The attorney has the burden of showing that the requested fee is reasonable, and the Court may require the attorney to submit a record of the hours spent representing the claimant and a statement of the attorney’s normal hourly billing rate for non-contingency fee cases. Id. at 807-08. Counsel’s requested fee does not exceed either the contractual agreement for 25% of Plaintiff’s past-due benefits or the limits of § 406(b). Applying the Gisbrecht factors, the Court concludes that the requested fee is reasonable. Counsel secured a fully favorable result for Plaintiff

3 in the form of a substantial past-due benefits award. Plaintiff’s success on appeal also enabled him to obtain $7,000.00 in attorney fees pursuant to the EAJA, although it appears that the full amount of this award was offset to satisfy a pre-existing debt Plaintiff owed to the United States. Moreover, there is no indication that Counsel caused any undue delay in these proceedings or represented

Plaintiff in a substandard manner. Finally, the Court has reviewed the contemporaneous time and expense records and finds the time expended to be reasonable and necessary considering the results obtained. These records indicate Counsel spent 35.6 hours of attorney time on this matter, which yields an hourly rate of approximately $787.91. The requested fee is not a “windfall” that should be reduced by the Court under Gisbrecht, especially considering the fee was contingent and lies within a range of Social Security contingency fee awards in this District.

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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)
Wrenn Ex Rel. Wrenn v. Astrue
525 F.3d 931 (Tenth Circuit, 2008)

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McCarthy v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccarthy-v-social-security-administration-oked-2025.