(SS) Lang v. Commissioner of Social Security

District Court, E.D. California·Decided April 11, 2024·No. 1:18-cv-01605·Unknown

Opinion

EASTERN DISTRICT OF CALIFORNIA

STEPHANIE LANG, Case No. 1:18-cv-01605-SKO Plaintiff, ORDER GRANTING PLAINTIFF’S v. COUNSEL’S MOTION FOR ATTORNEY’S FEES PURSUANT TO MARTIN O’MALLEY, 42 U.S.C. § 406(b) Acting Commissioner of Social Security1, (Doc. 23) Defendant. / I. INTRODUCTION On March 13, 2024, Stuart T. Barasch (“Counsel”), counsel for Plaintiff Stephanie Lang (“Plaintiff”), filed a motion for an award of attorney’s fees pursuant to 42 U.S.C. § 406(b) (“section 406(b)”). (Doc. 23.) On March 14, 2024, the Court issued a minute order requiring Plaintiff and the Commissioner to file their responses in opposition or statements of non-opposition to Counsel’s motion, if any, in accordance with this Court’s local rules. (Doc. 24.) Plaintiff and the Commissioner were served with copies of the motion for attorney’s fees. (Docs. 28, 29.) On March 20, 2024, the Commissioner filed a response, acknowledging it has “no direct financial stake in the outcome” of the motion, and therefore “neither supports nor opposes Counsel’s request for attorney’s fees under 42 U.S.C. § 406(b).” (Doc. 26 at 2.) Plaintiff did not file any objection to the motion by the deadline, and no reply brief was filed. (See Docket).

1 On December 20, 2023, Martin O’Malley was named Commissioner of the Social Security Administration. See https://www.ssa.gov/history/commissioners.html. 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 Office For the reasons set forth below, Counsel’s motion for an award of attorney’s fees is granted in the amount of $12,992.25, subject to an offset of $8,176.17 in fees already awarded pursuant to the Equal Access to Justice Act (“EAJA”), 28 U.S.C. § 2412(d), on July 28, 2020 (see Doc. 22). Plaintiff brought the underlying action seeking judicial review of a final administrative decision denying their claim for disability benefits under the Social Security Act. (Doc. 1.) The Court reversed the Commissioner’s denial of benefits and remanded the case to the agency for further proceedings. (Doc. 16.) Judgment was entered in favor of Plaintiff and against the Commissioner on March 12, 2020. (Doc. 17.) On June 4, 2020, Plaintiff filed a motion for attorney’s fees under the EAJA, which was granted in part in the amount of $8,176.17. (Docs. 18, 22.) On February 17, 2024, the Commissioner issued a letter to Plaintiff approving her claim for disability benefits and awarding her $80,769.00 in back payments beginning July 2014 through January 2021. (See Doc. 23-3; Doc. 23-1 at 2.) On March 13, 2024, Counsel filed a motion for attorney’s fees in the amount of $12,992.25, less than 25% of Plaintiff’s back benefits ($20,192.25), with an offset of $8,176.17 for EAJA fees already awarded. (Doc. 23.) It is Counsel’s motion for attorney’s fees that is currently pending before the Court. Pursuant to the Social Security Act, attorneys may seek a reasonable fee for cases in which they have successfully represented social security claimants. Section 406(b) provides the following: 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 allow as part of its judgment a reasonable fee for such representation, not in excess 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 the amount of such fee for payment to such attorney out of, and not in addition to, the amount of such past-due benefits . . . . 42 U.S.C. § 406(b)(1)(A) (emphasis added). “In contrast to fees awarded under fee-shifting provisions such as 42 U.S.C. § 1988, the fee is paid by the claimant out of the past-due benefits awarded; the losing party is not responsible for payment.” Crawford v. Astrue, 586 F.3d 1142, 1147 (9th Cir. 2009) (en banc) (citing Gisbrecht v. Barnhart, 535 U.S. 789, 802 (2002)). The Acting Commissioner has standing to challenge the award, despite that the section 406(b) attorney’s fee award is not paid by the government. Craig v. Sec’y Dep’t of Health & Human Servs., 864 F.2d 324, 328 (4th Cir. 1989), abrogated on other grounds in Gisbrecht, 535 U.S. at 807. The goal of fee awards under section 406(b) is to provide adequate incentive to represent claimants while ensuring that the usually meager disability benefits received are not greatly depleted. Cotter v. Bowen, 879 F.2d 359, 365 (8th Cir. 1989), abrogated on other grounds in Gisbrecht, 535 U.S. at 807. The 25% maximum fee is not an automatic entitlement, and courts are required to ensure that the requested fee is reasonable. Gisbrecht, 535 U.S. at 808–09 (Section 406(b) does not displace contingent-fee agreements within the statutory ceiling; instead, section 406(b) instructs courts to review for reasonableness fees yielded by those agreements). “Within the 25 percent boundary . . . the attorney for the successful claimant must show that the fee sought is reasonable for the services rendered.” Id. at 807; see also Crawford, 586 F.3d at 1148 (holding that section 406(b) “does not specify how courts should determine whether a requested fee is reasonable” but “provides only that the fee must not exceed 25% of the past-due benefits awarded”). Generally, “a district court charged with determining a reasonable fee award under § 406(b)(1)(A) must respect ‘the primacy of lawful attorney-client fee arrangements,’ . . . ‘looking first to the contingent-fee agreement, then testing it for reasonableness.’” Crawford, 586 F.3d at 1148 (quoting Gisbrecht, 535 U.S. at 793, 808). The United States Supreme Court has identified several factors that may be considered in determining whether a fee award under a contingent-fee agreement is unreasonable and therefore subject to reduction by the court: (1) the character of the representation; (2) the results achieved by the representative; (3) whether the attorney engaged in dilatory conduct in order to increase the accrued amount of past-due benefits; (4) whether the benefits are large in comparison to the amount of time counsel spent on the case; and (5) the attorney’s record of hours worked and counsel’s regular hourly billing charge for non-contingent cases. Id. (citing Gisbrecht, 535 U.S. at 807–08). Here, the fee agreement between Plaintiff and Counsel’s law firm, signed by both parties, provides in pertinent part: I understand that my federal court attorney also has the right to ask the court to award any remaining balance of 25% of my past-due benefits (“406(b) fees”) for representing me in federal court. My federal court attorney has this right if the representative, who represents me during remand proceedings, does not collect the full 25% of my past-due benefits during a remand proceeding; and also if (1) my case is

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Related

Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
United States v. Donald G. Auen
864 F.2d 4 (Second Circuit, 1988)
Crawford v. Astrue
586 F.3d 1142 (Ninth Circuit, 2009)
Clark v. Astrue
529 F.3d 1211 (Ninth Circuit, 2008)
Hearn v. Barnhart
262 F. Supp. 2d 1033 (N.D. California, 2003)