(SS) Pellegrini v. Commissioner of Social Security

CourtDistrict Court, E.D. California
DecidedJune 6, 2025
Docket2:21-cv-02312
StatusUnknown

This text of (SS) Pellegrini v. Commissioner of Social Security ((SS) Pellegrini 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) Pellegrini v. Commissioner of Social Security, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 NOEL BRITT PELLEGRINI, No. 2:21-cv-02312-SCR 12 Plaintiff, 13 v. ORDER 14 COMMISSIONER OF SOCIAL SECURITY, 15 16 Defendant. 17 18 Plaintiff sought judicial review of a final decision of the Commissioner of Social Security 19 (“Commissioner”), denying her application for benefits under the Social Security Act. On March 20 13, 2023, Magistrate Judge Barnes granted Plaintiff’s motion for summary judgment and entered 21 judgment remanding this action to the Commissioner for further proceedings. ECF Nos. 13 & 14. 22 On remand, Plaintiff was awarded past benefits of over $180,000.1 23 Now pending before the Court is Plaintiff’s January 16, 2025 Motion for an award of 24 attorney’s fees pursuant to 42 U.S.C. § 406(b). ECF No. 17. Plaintiff’s counsel seeks an award 25 of $39,000. Id. The Commissioner has filed a statement that he “neither supports nor opposes 26 1 The Notice of Award states: “Your past-due benefits are $185,460.” ECF No. 17-1 at 4. The 27 Notice further states Plaintiff will receive a check for $141,740.70. and that $39,165.00 was being withheld “in case your lawyer asks the Federal Court to approve a fee for work that was done 28 before the court” ECF No. 17-1 at 3. 1 counsel’s request for attorney’s fees.” ECF No. 19 at 2. The Commissioner requests that the 2 order direct Plaintiff’s counsel to reimburse Plaintiff any fees previously received under the Equal 3 Access to Justice Act (EAJA). Id. at 2-3. For the reasons set forth below, the Motion will be 4 granted. 5 I. REASONABLENESS OF FEE REQUEST 6 At the outset of the representation, Plaintiff and her counsel entered into a contingent-fee 7 agreement. ECF No. 17-3. Pursuant to that agreement Plaintiff’s counsel may seek 25% of past 8 due benefits awarded pursuant to 42 U.S.C. § 406(b). Id. The agreement further provides: “If 9 Francesco Benavides receives any attorney fees under 42 U.S.C. § 406(b), he shall pay to 10 Claimant any attorney fees he previously received under the Equal Access to Justice Act.” Id. 11 Plaintiff seeks attorney’s fees in the amount of $39,000.00 which is slightly less than 25% of the 12 retroactive disability benefits awarded to Plaintiff on remand. ECF No. 17 at 1.2 13 Attorneys are entitled to fees for cases in which they have successfully represented social 14 security claimants: 15 Whenever a court renders a judgment favorable to a claimant under this subchapter who was represented before the court by an attorney, 16 the court may determine and allow as part of its judgment a reasonable fee for such representation, not in excess of 25 percent of 17 the total of the past-due benefits to which the claimant is entitled by reason of such judgment, and the Commissioner of Social Security 18 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. 19 20 42 U.S.C. § 406(b)(1)(A). “In contrast to fees awarded under fee-shifting provisions such as 42 21 U.S.C. § 1988, the fee is paid by the claimant out of the past-due benefits awarded; the losing 22 party is not responsible for payment.” Crawford v. Astrue, 586 F.3d 1142, 1147 (9th Cir. 2009) 23 (en banc) (citing Gisbrecht v. Barnhart, 535 U.S. 789, 802 (2002)). The goal of fee awards under 24 § 406(b) is “to protect claimants against inordinately large fees and also to ensure that attorneys 25 representing successful claimants would not risk “nonpayment of [appropriate] fees.” Parrish v. 26

27 2 The attorney who represented Plaintiff at the administrative level has already received or is anticipated to receive $7,200 in fees. ECF No. 17 at 1. Thus, if this motion is granted the total 28 fee award to both attorneys would be $46,200, which is 24.9% of the $185,460 award. 1 Comm'r of Soc. Sec. Admin., 698 F.3d 1215, 1217 (9th Cir. 2012) (cleaned up). 2 The 25% statutory maximum fee is not an automatic entitlement, and the court must 3 ensure that the fee requested is reasonable. Gisbrecht, 535 U.S. at 808-09 (“406(b) does not 4 displace contingent-fee agreements within the statutory ceiling; instead, § 406(b) instructs courts 5 to review for reasonableness fees yielded by those agreements”). “Within the 25 percent 6 boundary . . . the attorney for the successful claimant must show that the fee sought is reasonable 7 for the services rendered.” Id. at 807. “[A] district court charged with determining a reasonable 8 fee award under § 406(b)(1)(A) must respect ‘the primacy of lawful attorney-client fee 9 arrangements,’ ‘looking first to the contingent-fee agreement, then testing it for reasonableness.’” 10 Crawford, 586 F.3d at 1149 (quoting Gisbrecht, 535 U.S. at 793, 808). 11 In determining whether the requested fee is reasonable, the court considers “‘the character 12 of the representation and the results achieved by the representative.’” Crawford, 586 F.3d 13 at 1151 (quoting Gisbrecht, 535 U.S. at 808). In determining whether a reduction in the fee is 14 warranted, the court considers whether the attorney provided “substandard representation or 15 delayed the case,” or obtained “benefits that are not in proportion to the time spent on the case.” 16 Id. Finally, the court considers the attorney’s record of hours worked and counsel’s regular 17 hourly billing charge for non-contingent cases. Crawford, 586 F.3d at 1151-52 (citing Gisbrecht, 18 535 U.S. at 808); see also, E.D. Cal. R. 293(c)(1) (in fixing attorney’s fees the court considers 19 “the time and labor required”). Below, the Court will consider these factors in assessing whether 20 the fee requested by counsel in this case pursuant to 42 U.S.C. § 406(b) is reasonable. 21 Here, Plaintiff’s counsel, Francesco Benavides, is an experienced attorney who secured a 22 successful result for Plaintiff. Plaintiff’s counsel represents that he has been practicing Social 23 Security law for nearly 15 years. ECF No. 17 at 6.3 However, the majority of the time billed on 24 the case was by another attorney, Freddie Effinger, and the initial motion provided no information 25 about his qualifications or experience. Accordingly, the Court directed counsel to provide 26

27 3 Page number citations such as this one are to the page number reflected on the header generated by the court’s CM/ECF system and not to page numbers assigned by the parties. 28 1 additional information. ECF No. 20. In response, Plaintiff provided the supplemental declaration 2 of Mr. Effinger. ECF No. 21-1. Mr. Effinger’s declaration states he was admitted to practice in 3 2009, and has been specializing in social security disability law since he joined the Social 4 Security Administration as an attorney advisor in 2010. ECF No. 21-1 at ¶¶ 3-4. Mr. Effinger 5 then began working in private practice representing claimants in disability cases in 2019. Id. at ¶¶ 6 8-9. There is no indication that a reduction of fees is warranted due to any substandard 7 performance by counsel.

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Related

Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Crawford v. Astrue
586 F.3d 1142 (Ninth Circuit, 2009)

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Bluebook (online)
(SS) Pellegrini v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ss-pellegrini-v-commissioner-of-social-security-caed-2025.