M.F. v. Kijakazi

CourtDistrict Court, N.D. California
DecidedMay 1, 2022
Docket3:20-cv-08742
StatusUnknown

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

Bluebook
M.F. v. Kijakazi, (N.D. Cal. 2022).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 NORTHERN DISTRICT OF CALIFORNIA 8

10 M. F., 11 Plaintiff, No. C 20-08742 WHA

12 v.

13 KILOLO KIJAKAZI, ORDER RE PLAINTIFF'S MOTION FOR ATTORNEY'S FEES 14 Defendant.

15 16 17 INTRODUCTION 18 In this social security appeal, plaintiff requests an award of attorney’s fees and costs 19 under the Equal Access to Justice Act. To the extent stated, the motion is GRANTED IN PART 20 and DENIED IN PART. 21 STATEMENT 22 Plaintiff M.F., proceeding pseudonymously, applied for disability benefits, which an 23 administrative law judge denied. Plaintiff appealed that decision to federal district court, 24 whereupon an order herein granted plaintiff’s motion for summary judgment and remanded the 25 matter to the Acting Commissioner for further proceedings (Dkt. No. 25). Specifically, the 26 order found that the ALJ erred by failing to address plaintiff’s stated severe sensitivity to the 27 side effects of psychiatric drugs when discounting her symptom testimony due to her lack of 1 costs under the Equal Access to Justice Act (EAJA) and requests that the fees be paid directly 2 to her attorney. The Acting Commissioner opposes only as to the reasonableness of plaintiff’s 3 requested award. 4 ANALYSIS 5 The EAJA provides that a party can receive attorney’s fees if: (1) the party “prevails” in 6 the civil action, and (2) the government’s position in the action, including the underlying 7 administrative proceedings, was not “substantially justified.” 28 U.S.C. § 2412(d)(1)(A). 8 First, given that a previous order herein granted plaintiff’s summary judgment motion 9 and remanded to the Acting Commissioner for further proceedings, plaintiff is the prevailing 10 party for the purposes of the EAJA. See Gutierrez v. Barnhart, 274 F.3d 1255, 1257 (9th Cir. 11 2001). Second, the Acting Commissioner asserts no special circumstances and does not 12 dispute that the government’s position fell short of substantially justified. See Meier v. Colvin, 13 727 F.3d 867, 870 (9th Cir. 2013). This order agrees with the parties that plaintiff is entitled to 14 attorney’s fees. 15 1. REASONABLENESS OF FEES AND EXPENSES. 16 A plaintiff bears the burden of establishing the reasonableness of the requested fee award 17 under the EAJA. A plaintiff must thereby document the appropriate hours spent in litigation 18 by submitting evidence in support of those hours worked. Gates v. Deukmejian, 987 F.2d 19 1392, 1397 (9th Cir. 1992). The appropriate number of billable hours consists of those hours 20 “reasonably expended in pursuit of the ultimate result achieved, in the same manner that an 21 attorney traditionally is compensated by a fee-paying client for all time reasonably expended 22 on a matter.” Hensley v. Eckerhart, 461 U.S. 424, 431 (1983) (quotation omitted). “Counsel 23 for the prevailing party should make a good faith effort to exclude from a fee request hours that 24 are excessive, redundant, or otherwise unnecessary.” Id. at 434. It follows that fee-shifting 25 does not extend to effort expended on issues not actually adjudicated. Id. at 435; Hardisty v. 26 Astrue, 592 F.3d 1072, 1077 (9th. Cir. 2010). 27 When awarding attorney’s fees, district courts have discretion to reduce the number of 1 (9th Cir. 2012). The time entries submitted with the instant motion show a total 134.65 hours 2 of work (Billing Entries, Bruce Decl. Exh. A). Three lawyers contributed to this matter: 3 Attorney Steven Bruce (SB); Attorney Susan Widule (SW); and Attorney April Benerjee (AB). 4 This order finds a forty-percent reduction to the number of hours expended by counsel in this 5 action warranted and awards $17,466.72 in attorney’s fees for the following reasons. 6 First, plaintiff’s counsel billed for time spent researching and drafting several issues 7 raised in the motion for summary judgment that the corresponding order never adjudicated. At 8 least eight pages of the twenty-five-page opening brief were devoted to material not considered 9 in the remand order. Many of the arguments the remand order ultimately did not consider were 10 unfocused and unavailing. See Reyna v. Comm’r of Soc. Sec., 548 Fed. App’x 404, 405 (9th 11 Cir. 2013). Accordingly, at least thirty-two percent (8/25) of the work on the motion for 12 summary judgment should not be compensated (Billing Entry Nos. 35–64). Given that counsel 13 billed 104.95 hours towards the summary judgment motion, a reduction of at least 33.6 hours is 14 appropriate. 15 Second, while counsel achieved a favorable result for plaintiff, that success remained 16 modest. “If . . . a plaintiff has achieved only partial or limited success, the product of hours 17 reasonably expended on the litigation as a whole times a reasonable hourly rate may be an 18 excessive amount. This will be true even where the plaintiff’s claims were interrelated, 19 nonfrivolous, and raised in good faith.” Hensley, 461 U.S. at 436. Yes, the remand order 20 found that the ALJ had erred by failing to address plaintiff’s sensitivity to medication. 21 However, that order did not award benefits but remanded for further proceedings. Moreover, 22 the remand order explicitly stated that it “in no way suggests that the ALJ should change her 23 mind on the ultimate issue of disability (or suggests she should not change her mind). Rather, 24 this remand is ordered out of an abundance of caution to make sure the ALJ’s explanation is 25 adequate under circuit law” (Dkt. No. 25 at 9–10). This order finds full attorney’s fees 26 unwarranted here because plaintiff achieved a narrow remand. 27 Third, various time entries are inaccurate and inflated. For example, billing entry 21 on 1 complaint (and amended complaint) five days prior, on December 10, 2020 (Dkt. Nos. 1, 3). 2 No further explanation is given. Billing entry 20, also dated December 15, states “Read 3 Complaint.” Billing the time spent reading your client’s own complaint ranks as excessive. 4 As another example, billing entry 57 registered 1.25 hours for “open and save document 21, 5 22,” presumably referencing Dkt. Nos. 21 and 22 for this matter. This order finds it difficult to 6 understand how 1 hour and 15 minutes could be dedicated to downloading two documents 7 from ECF. This task should only take minutes to accomplish at most. These entries inevitably 8 suggest that other entries may be similarly inaccurate or bloated, which warrants reductions in 9 total billable hours. 10 Fourth, this order finds many billing entries duplicative. For example: 11 No. Date Description Hour(s) Staff 1 11/12/2020 email to Deborah Stachel regarding extension, 2.5 SB 12 research protective order 13 2 11/12/2020 email to Deborah Stachel regarding extension, 1.75 SW research protective order 14 23 12/16/2020 Approximately 5 emails to OGC on 30 day 0.2 SB extension, Goulseth, Deborah Stachel (Regional 15 Chief Counsel) 16 24 12/16/2020 Approximately 5 emails to OGC on 30 day 0.4 SW extension, Goulseth, Deborah Stachel (Regional 17 Chief Counsel) 18 Two lawyers were not required to perform these tasks. More concerning, both sets of entries 19 have the same exact wording, which suggests counsel did not record their entries 20 contemporaneously but reconstructed them after the fact. Counsel does not state that the 21 entries were created contemporaneously (Bruce Decl. ¶ 7). Non-contemporaneous billing is 22 less reliable and susceptible to time inflation and justifies adjustments. See Hensley, 461 U.S. 23 at 438 n.13.

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Astrue v. Ratliff
560 U.S. 586 (Supreme Court, 2010)
Jeffrey Meier v. Carolyn W. Colvin
727 F.3d 867 (Ninth Circuit, 2013)
Hardisty v. Astrue
592 F.3d 1072 (Ninth Circuit, 2010)
Rodriguez v. United States
542 F.3d 704 (Ninth Circuit, 2008)
Rahinah Ibrahim v. US Dept. of Homeland Security
912 F.3d 1147 (Ninth Circuit, 2019)

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M.F. v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mf-v-kijakazi-cand-2022.