(SS) Trapp v. Commissioner of Social Security

District Court, E.D. California·Decided November 10, 2021·No. 1:19-cv-00742·Unknown

Opinion

ANNA LYNN TRAPP, Case No. 1:19-cv-00742-AWI-EPG Plaintiff, v. ORDER GRANTING PLAINTIFF’S COUNSEL’S MOTION FOR ATTORNEY’S COMMISSIONER OF SOCIAL FEES PURSUANT TO 42 U.S.C. § 406(b) SECURITY, (ECF No. 26) Defendant.

Before the Court is a motion for an award of attorney’s fees pursuant to 42 U.S.C. § 406(b) filed by Shellie Lott, counsel for Plaintiff Anna Lynn Trapp (“Plaintiff”). (ECF No. 26.) For the following reasons, the motion for an award of attorney’s fees is GRANTED in the amount of $14,722.75. Plaintiff’s counsel shall reimburse Plaintiff for the $7,050.00 in fees and costs previously awarded pursuant to the Equal Access to Justice Act (“EAJA”). (See ECF No. 25.) I. BACKGROUND Plaintiff brought the underlying action seeking judicial review of a final administrative decision denying her claim for Disability Insurance Benefits under the Social Security Act. (ECF No. 1.) On January 23, 2019, Plaintiff filed her opening brief. (ECF No. 18.) On March 19, 2020, the parties filed a stipulation agreeing to a voluntary remand of this case pursuant to sentence for of 42 U.S.C. § 405(g). (ECF No. 21.) The Court entered an order approving the stipulation and judgment was entered on March 19, 2020. (ECF Nos. 22, 23.) On May 7, 2020, the parties filed a stipulation for an award of $7,050.00 in attorneys’ fees under EAJA. (ECF No. 24.) Senior District Judge Anthony W. Ishii entered an order awarding attorneys’ fees under EAJA pursuant to the stipulation. (ECF No. 25.) On remand, an administrative law judge held a hearing on February 23, 2021, which resulted in a fully favorable decision dated April 8, 2021. (ECF No. 26-1 at 1.) The Commissioner awarded $58,891.00 in past-due benefits to Plaintiff. (ECF No. 26-2 at 5.) On August 19, 2021, Plaintiff’s counsel filed a motion seeking attorneys’ fees in the amount of $14,722.75 pursuant to 42 U.S.C. § 406(b), with a credit to Plaintiff for the EAJA fees previously awarded. (ECF No. 26.) Plaintiff and the Commissioner of Social Security were each served with a copy of the motion. (ECF No. 26 at 3.) The Commissioner has filed a response to the motion neither assenting nor objecting to the requested fees. (ECF No. 27.) On September 28, 2021, the Court granted Plaintiff’s counsel leave to file supplemental briefing in support of the motion addressing the reasonableness of the requested fee award. (ECF No. 28.) On October 12, 2021, Plaintiff’s counsel filed a supplemental brief in support of the motion. (ECF No. 29.) The supplemental brief was also served on Plaintiff and the Commissioner. (ECF No. 29 at 5.) Plaintiff has not filed an objection or any other response to the motion. 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:

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 [406(b)] 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)). Even though the section 406(b) attorney fees award is not paid by the government, the Commissioner has standing to challenge the award. 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 (holding that 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 Plaintiff’s counsel, which is signed by Plaintiff, provides:

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Related

Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Craig v. Secretary
864 F.2d 324 (Fourth Circuit, 1989)
Crawford v. Astrue
586 F.3d 1142 (Ninth Circuit, 2009)
Patterson Ex Rel. Chaney v. Apfel
99 F. Supp. 2d 1212 (C.D. California, 2000)
Hearn v. Barnhart
262 F. Supp. 2d 1033 (N.D. California, 2003)