(SS) Howell v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedFebruary 20, 2024
Docket1:19-cv-01704
StatusUnknown

This text of (SS) Howell v. Commissioner of Social Security ((SS) Howell 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) Howell v. Commissioner of Social Security, (E.D. Cal. 2024).

Opinion

4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 JOHN W. HOWELL, Case No. 1:19-cv-01704-EPG 11 Plaintiff, ORDER GRANTING, IN PART, MOTION 12 FOR ATTORNEY’S FEES PURSUANT 13 v. TO 42 U.S.C. § 406(b) COMMISSIONER OF SOCIAL SECURITY, 14 (ECF No. 23) Defendant. 15 16 On October 2, 2023, Attorney Young Cho, counsel for Plaintiff John W. Howell, filed a 17 motion for an award of attorney’s fees under 42 U.S.C. § 406(b). (ECF No. 23). Plaintiff and the 18 Commissioner of Social Security were each served with a copy of the motion. (ECF No. 25). 19 Plaintiff has not filed any response to the motion. On October 23, 2023, the Commissioner filed a 20 response providing analysis regarding the fee request but taking no position on its reasonableness. 21 (ECF No. 26). The parties have consented to entry of final judgment by the United States 22 Magistrate Judge under the provisions of 28 U.S.C. § 636(c) with any appeal to the Court of 23 Appeals for the Ninth Circuit. (ECF No. 18). 24 For the reasons set forth below, the motion for attorney’s fees is granted in part, in the 25 amount of $17,800.00, subject to an offset of $3,400.00 in fees already awarded pursuant to the 26 Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412(d), on November 5, 2020 (ECF No. 22). 27 // 28 1 I. BACKGROUND 2 Plaintiff filed the complaint in this case on December 5, 2019. (ECF No. 1). 3 On September 23, 2020, the parties filed a stipulation for voluntary remand for further 4 proceedings pursuant to Sentence Four of 42 U.S.C. § 405(g). (ECF No. 17). On September 24, 2020, the Court entered an order approving the parties’ stipulation and entering judgment in favor 5 of Plaintiff. (ECF No. 19). On November 5, 2020, pursuant to the parties’ stipulation, the Court 6 entered an order awarding Plaintiff $3,400 in EAJA fees. (ECF Nos. 21, 22). 7 On remand, the Commissioner held further proceedings and determined Plaintiff was 8 entitled to disability insurance benefits. (ECF No. 23, p. 5). The Commissioner calculated 9 Plaintiff’s past-due benefits at $119,480.00 and 25%, i.e., $29,870.00, was withheld to pay 10 Plaintiff’s representative. (ECF No. 23, p. 3; ECF No. 23-3, pp. 1- 2). This matter is now before 11 the Court on counsel’s motion, seeking an award of $24,000.00. (ECF No. 23). 12 II. DISCUSSION 13 Under the Social Security Act, attorneys may seek a reasonable fee for cases in which 14 they have successfully represented social security claimants. Section 406(b) provides: 15 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 16 allow as part of its judgment a reasonable fee for such representation, not in excess 17 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 . . . 18 certify the amount of such fee for payment to such attorney out of, and not in addition to, the amount of such past-due benefits . . . . 19 42 U.S.C. § 406(b)(1)(A) (emphasis added). 20 “In contrast to fees awarded under fee-shifting provisions such as 42 U.S.C. § 1988, the 21 [§ 406(b)] fee is paid by the claimant out of the past-due benefits awarded; the losing party is not 22 responsible for payment.” Crawford v. Astrue, 586 F.3d 1142, 1147 (9th Cir. 2009) (en banc) 23 (citing Gisbrecht v. Barnhart, 535 U.S. 789, 802 (2002)). Even though the § 406(b) fee award is 24 not paid by the Government, the Commissioner “plays a part in the fee determination resembling 25 that of a trustee for the claimant[].” Gisbrecht, 535 U.S. at 798 n. 6. The goal of awarding fees 26 under § 406(b) was to prohibit “exorbitant fees” from being collected by attorneys but also to 27 provide sufficient fee awards “to encourage adequate representation of claimants.” Crawford, 586 28 1 F.3d at 1149 (internal citations omitted). 2 The 25% maximum fee is not an automatic entitlement, and courts are required to ensure 3 that the requested fee is reasonable. Gisbrecht, 535 U.S. at 808-09 (holding that § 406(b) does not 4 displace contingent-fee agreements within the statutory ceiling; instead, § 406(b) instructs courts to review for reasonableness fees yielded by those agreements). “Within the 25 percent boundary 5 . . . the attorney for the successful claimant must show that the fee sought is reasonable for the 6 services rendered.” Id. at 807; see also Crawford, 586 F.3d at 1148 (noting that § 406(b) “does 7 not specify how courts should determine whether a requested fee is reasonable” but “provides 8 only that the fee must not exceed 25% of the past-due benefits awarded”). 9 Generally, “a district court charged with determining a reasonable fee award under 10 § 406(b)(1)(A) must respect ‘the primacy of lawful attorney-client fee arrangements,’ . . . 11 ‘looking first to the contingent-fee agreement, then testing it for reasonableness.’” Crawford, 586 12 F.3d at 1148 (quoting Gisbrecht, 535 U.S. at 808). The United States Supreme Court has 13 identified several factors that may be considered in determining whether a fee award under a 14 contingent-fee agreement is unreasonable and therefore subject to reduction: (1) the character of 15 the representation; (2) the results achieved by the representative; (3) whether the attorney engaged 16 in dilatory conduct in order to increase the accrued amount of past-due benefits; (4) whether the 17 benefits are large in comparison to the amount of time counsel spent on the case; and (5) the 18 attorney’s record of hours worked. Id. (citing Gisbrecht, 535 U.S. at 807-08). 19 Here, Counsel Cho seeks an award of $24,000 under 42 U.S.C. § 406(b) for 15.6 hours of 20 attorney time and 2.2 hours of paralegal time. (ECF No. 23, p. 16; ECF No. 23-4). The requested 21 amount is equivalent to 20.1% of the past due benefits payable to Plaintiff. (ECF No. 23, p. 11). 22 The fee agreement signed by Plaintiff at the outset of litigation specifically provides for a 23 fee of “25% of the past due benefits awarded upon reversal of any unfavorable ALJ decision for work before the Social Security Administration” as well as a “separate” fee equal to “25% of the 24 past due benefits awarded upon reversal of any unfavorable ALJ decision for work before the 25 court.” (ECF No. 23-1, p. 1). Counsel represents that he intends to seek additional fees under 42 26 U.S.C. § 406(a) for worked performed before the Administration in the amount of $10,000.00.1 27

28 1 The total aggregate fees sought by counsel under §§ 406(a) and (b) will amount to $34,000.00. This is 1 (Id., p. 10). Counsel Cho’s declaration states that he “will apply a remittitur so that the aggregate 2 of all fees received by counsel and counsel’s firm from administrative and Court awards will not 3 exceed the withholding in this case,” i.e., $29, 870.00. (Id., p. 16).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Crawford v. Astrue
586 F.3d 1142 (Ninth Circuit, 2009)
Hearn v. Barnhart
262 F. Supp. 2d 1033 (N.D. California, 2003)
Culbertson v. Berryhill
586 U.S. 53 (Supreme Court, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
(SS) Howell v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ss-howell-v-commissioner-of-social-security-caed-2024.