Mitchell v. Kijakazi

CourtDistrict Court, S.D. California
DecidedAugust 25, 2025
Docket3:22-cv-01649
StatusUnknown

This text of Mitchell v. Kijakazi (Mitchell 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
Mitchell 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 Case No.: 22-cv-1649-DMS-KSC MARY MITCHELL,

12 Plaintiff, ORDER GRANTING IN PART 13 v. MOTION FOR ATTORNEY’S FEES AND DENYING COSTS 14 FRANK BISIGNANO, Commissioner of

Social Security, 15 Defendant. 16

17 18 Pending before the Court is a Motion filed by Plaintiff’s attorney, Alexandra 19 Manbeck, for an award of attorney’s fees and costs pursuant to the Equal Access to Justice 20 Act (“EAJA”), 28 U.S.C. § 2412. (Mot., ECF No. 31-1). Defendant filed a Response in 21 Opposition. (Opp’n, ECF No. 39). Thereafter, Plaintiff Mary Mitchell filed an 22 “Application to file a Declaration” in response to Ms. Manbeck’s Motion. (ECF No. 41). 23 Ms. Manbeck filed a Reply, (Reply, ECF No 42), and Defendant filed a Motion to Strike 24 the Reply, or in the alternative, to file a Sur-Reply. (ECF No. 43). The Court denies 25 Defendant’s Motion to Strike and accepts the Reply, Sur-Reply, and Plaintiff’s 26 Declaration. The matter is submitted on the briefs without oral argument pursuant to Civil 27 Local Rule 7.1(d)(1). (ECF No. 40). For the following reasons, the Court finds Ms. 28 Manbeck is entitled to reasonable attorney’s fees in the amount of $29,212.47, but no costs. 1 I. BACKGROUND 2 This matter came before the Court following an Administrative Law Judge’s 3 (“ALJ”) denial of Plaintiff’s application for a period of disability benefits and disability 4 insurance benefits. (Compl., ECF No. 1, at 2). Following denial of her appeal of the ALJ’s 5 decision, Plaintiff, proceeding pro se, filed the instant action on October 24, 2022. (Id.). 6 Plaintiff filed her “motion for summary judgment” on July 21, 2023, requesting reversal of 7 the ALJ’s order and subsequent remand, or, alternatively, remand for an order of benefits 8 to Plaintiff. (ECF No. 18, at 25). Defendant agreed that the matter should be remanded to 9 the ALJ for further proceedings but opposed Plaintiff’s request for an order of benefits. 10 (ECF No. 20). On November 9, 2023, Magistrate Judge Crawford issued a Report and 11 Recommendation to deny Plaintiff’s motion for summary judgment and remand for an 12 order of benefits. (R&R, ECF No. 25). 13 Thereafter, Ms. Manbeck filed a Notice of Appearance as counsel of record on 14 January 2, 2024. (ECF No. 28) (“Notice is hereby given that Plaintiff hereby appoints the 15 undersigned, Alexandra T. Manbeck, as her attorney of record in the above-captioned 16 case.”). Plaintiff, with the assistance of Ms. Manbeck, objected to Judge Crawford’s R&R 17 and argued that the case should be remanded for the calculation of award of benefits. (ECF 18 No. 29). On February 26, 2024, the Court overruled Plaintiff’s objections and adopted 19 Judge Crawford’s R&R after de novo review. (ECF No. 30). On April 25, 2024, Plaintiff, 20 now proceeding pro se, filed an appeal of this Court’s Order adopting Judge Crawford’s 21 R&R to the Ninth Circuit. (ECF No. 33). On October 7, 2024, the Ninth Circuit dismissed 22 Plaintiff’s appeal for failure to prosecute. (ECF No. 46). 23 On March 18, 2024, Ms. Manbeck filed the subject Motion. Counsel requests fees 24 for billable work advising Plaintiff on a wide range of matters relating to the filing of 25 Plaintiff’s complaint through appeal to the Ninth Circuit, and for preparing the present 26 Motion and related briefing. (ECF No. 31-2, at 5). She claims her billable work began on 27 September 28, 2022, and concluded on July 19, 2024. (Id. at 4–5); (Reply). Plaintiff, in 28 her declaration, appears not to oppose Ms. Manbeck’s request for attorney’s fees, but states 1 the Motion was filed “without [her] knowledge or consent.” (ECF No. 41, at 3). Plaintiff 2 also states Ms. Manbeck only agreed to provide “advice and help occasionally,” while 3 Plaintiff represented herself from 2022 to 2024. (ECF No. 41, at 2). According to Plaintiff, 4 Ms. Manbeck’s representation began on January 2, 2024, when she entered her formal 5 appearance, and she only assisted with drafting some of Plaintiff’s objections to Judge 6 Crawford’s R&R. (Id. at 3). Plaintiff also claims Ms. Manbeck declined to file Plaintiff’s 7 appeal and advised her to proceed pro se. (Id. at 4). 8 II. LEGAL STANDARD 9 Under the EAJA, a court shall award a “prevailing party” all reasonable attorney’s 10 fees, costs, and other expenses “incurred by that party in any civil action (other than cases 11 sounding in tort), including proceedings for judicial review of agency action, brought by 12 or against the United States in any court having jurisdiction of that action, unless the court 13 finds that the position of the United States was substantially justified or that special 14 circumstances make an award unjust.” 28 U.S.C. § 2412(d)(1)(A). Plaintiff is entitled to 15 attorney’s fees under the EAJA if (1) the claimant is a “prevailing party”; (2) the 16 government’s position was not “substantially justified”; (3) no special circumstances make 17 the fee award unjust; and (4) pursuant to 28 U.S.C. § 2412(d)(1)(B), any fee application is 18 submitted to the Court within 30 days of final judgment in the action and is supported by 19 an itemized statement. Comm’r I.N.S. v. Jean, 496 U.S. 154, 158 (1990). 20 III. DISCUSSION 21 Defendant advances six arguments against an award of attorney’s fees. First, under 22 the fourth EAJA factor, Plaintiff’s request for attorney’s fees is premature because no final 23 judgment has been entered. (Opp’n at 4–9). Second, and relatedly, Plaintiff is not a 24 prevailing party because no final judgment has been entered. (Id. at 9). Third, Plaintiff is 25 not entitled to fees incurred while Plaintiff represented herself because pro se litigants 26 cannot recover fees under the EAJA. (Id. at 9–12). Fourth, under the “special 27 circumstances” EAJA factor, Plaintiff should not be entitled to any attorney’s fees because 28 Ms. Manbeck’s work on Plaintiff’s objections to Judge Crawford’s R&R was unsuccessful 1 and did not materially enhance Plaintiff’s position. (Id. at 17–20). Fifth, even if Plaintiff 2 is entitled to attorney’s fees under the EAJA, the amount should be reduced to zero because 3 Plaintiff’s objections were unsuccessful. (Id. at 12–14). Sixth, to the extent Ms. Manbeck 4 is entitled to fees, she should not receive a rate enhancement. (Id. at 14–17). Each 5 argument is addressed in turn. 6 A. Timeliness 7 The EAJA mandates that an application for an award of fees and other expenses shall 8 be submitted to the court “within thirty days of final judgment in the action.” 28 U.S.C. 9 § 2412(d)(1)(B). A final judgment is defined as “a judgment that is final and not 10 appealable, and includes an order of settlement.” 28 U.S.C. § 2412(d)(2)(G). Because the 11 government is a party, the thirty-day deadline to file an application for fees and costs under 12 the EAJA would be sixty days post the Court’s February 26, 2024 Order, or April 26, 2024, 13 if no appeal was filed in this case. See Fed. R. App. P. 4(a)(1); Yang v. Shalala, 22 F.3d 14 213, 215–16 (9th Cir. 1994). Of course, as discussed, Plaintiff did file an appeal. (ECF 15 No. 33).

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Mitchell v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-v-kijakazi-casd-2025.