(SS) Averill-Marcogliese v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedMay 29, 2025
Docket1:21-cv-00277
StatusUnknown

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

Bluebook
(SS) Averill-Marcogliese v. Commissioner of Social Security, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 SAMANTHA REGINA AVERILL- Case No. 1:21-cv-00277-SKO 12 MARCOGLIESE, ORDER GRANTING PLAINTIFF’S 13 Plaintiff, COUNSEL’S MOTION FOR ATTORNEY’S FEES PURSUANT TO 14 v. 42 U.S.C. § 406(b) FRANK BISIGNANO, 15 Commissioner of Social Security1, (Doc. 23) / 16 Defendant. 17 I. INTRODUCTION 18 On April 28, 2025, Jonathan O. Pena (“Counsel”), counsel for Plaintiff Samantha Regina 19 Averill-Marcogliese (“Plaintiff”), filed a motion for an award of attorney’s fees pursuant to 42 20 U.S.C. § 406(b) (“section 406(b)”). (Doc. 23.) That same day, the Court issued a minute order 21 requiring Plaintiff and the Commissioner to file their responses in opposition or statements of non- 22 opposition to Counsel’s motion, if any, in accordance with the Local Rules. (Doc. 25.) Plaintiff 23 and the Commissioner were served with copies of the motion for attorney’s fees and the minute 24 order. (Docs. 24, 28.) 25 26 1 On May 6, 2025, Frank Bisignano was appointed the Commissioner of the Social Security Administration. See 27 https://www.ssa.gov/news/press/releases/2025/#2025-05-07. He is therefore substituted as the defendant in this action. See 42 U.S.C. § 405(g) (referring to the “Commissioner’s Answer”); 20 C.F.R. § 422.210(d) (“the person holding the 28 Office of the Commissioner shall, in his official capacity, be the proper defendant”). 1 On April 29, 2025, the Commissioner filed a response, indicating that he “neither supports 2 nor opposes counsel’s request for attorney’s fees.” (See Doc. 27 at 2, 3.) Plaintiff did not file any 3 objection to the motion by the deadline, and no reply brief was filed. (See Docket.) 4 For the reasons set forth below, Counsel’s motion for an award of attorney’s fees is granted 5 in the amount of $20,700, subject to an offset of $5,100 in fees already awarded pursuant to the 6 Equal Access to Justice Act (“EAJA”), 28 U.S.C. § 2412(d), on September 21, 2023 (see Doc. 22). II. BACKGROUND 7 8 Plaintiff brought the underlying action seeking judicial review of a final administrative 9 decision denying her claim for disability benefits under the Social Security Act. (Doc. 1.) The 10 Court reversed the Commissioner’s denial of benefits and remanded the case to the agency for 11 further proceedings. (Doc. 17.) Judgment was entered in favor of Plaintiff and against the Acting 12 Commissioner on June 21, 2023. (Doc. 18.) The parties stipulated to an award of $5,100 in attorney 13 fees under EAJA, which was entered on September 22, 2023. (Docs. 21, 22.) 14 On April 13, 2025, the Commissioner issued a letter to Plaintiff approving her claim for 15 disability benefits and awarding her $108,504 in back payments beginning December 2013. (See 16 Doc. 23-2.) On April 28, 2025, Counsel filed a motion for attorney’s fees in the amount of $20,700, 17 which is less than 25% of Plaintiff’s back benefits, with an offset of $5,100 for EAJA fees already 18 awarded. (Doc. 23) It is Counsel’s motion for attorney’s fees that is currently pending before the 19 Court. III. DISCUSSION 20 21 Pursuant to the Social Security Act, attorneys may seek a reasonable fee for cases in which 22 they have successfully represented social security claimants. Section 406(b) provides the following: 23 Whenever a court renders a judgment favorable to a claimant under this subchapter who was represented before the court by an attorney, the court may determine and 24 allow as part of its judgment a reasonable fee for such representation, not in excess 25 of 25 percent of the total of the past-due benefits to which the claimant is entitled by reason of such judgment, and the Commissioner of Social Security may . . . certify 26 the amount of such fee for payment to such attorney out of, and not in addition to, the amount of such past-due benefits . . . . 27 28 42 U.S.C. § 406(b)(1)(A) (emphasis added). “In contrast to fees awarded under fee-shifting 1 provisions such as 42 U.S.C. § 1988, the fee is paid by the claimant out of the past-due benefits 2 awarded; the losing party is not responsible for payment.” Crawford v. Astrue, 586 F.3d 1142, 1147 3 (9th Cir. 2009) (en banc) (citing Gisbrecht v. Barnhart, 535 U.S. 789, 802 (2002)). The Acting 4 Commissioner has standing to challenge the award, despite that the section 406(b) attorney’s fee 5 award is not paid by the government. Craig v. Sec’y Dep’t of Health & Human Servs., 864 F.2d 6 324, 328 (4th Cir. 1989), abrogated on other grounds in Gisbrecht, 535 U.S. at 807. The goal of 7 fee awards under section 406(b) is to provide adequate incentive to represent claimants while 8 ensuring that the usually meager disability benefits received are not greatly depleted. Cotter v. 9 Bowen, 879 F.2d 359, 365 (8th Cir. 1989), abrogated on other grounds in Gisbrecht, 535 U.S. at 10 807. 11 The 25% maximum fee is not an automatic entitlement, and courts are required to ensure 12 that the requested fee is reasonable. Gisbrecht, 535 U.S. at 808–09 (Section 406(b) does not displace 13 contingent-fee agreements within the statutory ceiling; instead, section 406(b) instructs courts to 14 review for reasonableness fees yielded by those agreements). “Within the 25 percent boundary . . . 15 the attorney for the successful claimant must show that the fee sought is reasonable for the services 16 rendered.” Id. at 807; see also Crawford, 586 F.3d at 1148 (holding that section 406(b) “does not 17 specify how courts should determine whether a requested fee is reasonable” but “provides only that 18 the fee must not exceed 25% of the past-due benefits awarded”). 19 Generally, “a district court charged with determining a reasonable fee award under 20 § 406(b)(1)(A) must respect ‘the primacy of lawful attorney-client fee arrangements,’ . . . ‘looking 21 first to the contingent-fee agreement, then testing it for reasonableness.’” Crawford, 586 F.3d at 22 1148 (quoting Gisbrecht, 535 U.S. at 793, 808). The United States Supreme Court has identified 23 several factors that may be considered in determining whether a fee award under a contingent-fee 24 agreement is unreasonable and therefore subject to reduction by the court: (1) the character of the 25 representation; (2) the results achieved by the representative; (3) whether the attorney engaged in 26 dilatory conduct in order to increase the accrued amount of past-due benefits; (4) whether the 27 benefits are large in comparison to the amount of time counsel spent on the case; and (5) the 28 attorney’s record of hours worked and counsel’s regular hourly billing charge for non-contingent 1 cases. Id. (citing Gisbrecht, 535 U.S. at 807–08).

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(SS) Averill-Marcogliese v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ss-averill-marcogliese-v-commissioner-of-social-security-caed-2025.