Vanderzwet v. Kijakazi

District Court, S.D. Texas·Decided October 7, 2024·No. 4:23-cv-02307·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT October 07, 2024 FOR THE SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

§ TERI JUNE VANDERZWET.,1 § § Plaintiff, § § v. § Case No. 4:23-cv-2307 § MARTIN O’MALLEY,2 § Commissioner of Social Security, § § Defendant. § § §

MEMORANDUM AND ORDER Plaintiff seeks to recover attorney’s fees and costs pursuant to the Equal Access to Justice Act (“EAJA”), 28 U.S.C. § 2412. Pl.’s Mot., ECF No. 22. Because the Court granted Plaintiff’s Motion for Summary Judgment, ECF No. 14, and remanded this case to the Commissioner for reconsideration, Memorandum & Order, ECF No. 20; Final Judgment, ECF No. 21, Plaintiff is the prevailing party.3 The

1 Pursuant to the May 1, 2018 “Memorandum Re: Privacy Concern Regarding Social Security and Immigration Opinions” issued by the Committee on Court Administration and Case Management of the Judicial Conference of the United States, the Court uses only Plaintiff’s first name and last initial.

2 Martin O’Malley became the Commissioner of Social Security on December 20, 2023. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Martin O’Malley should be substituted for Kilolo Kijakazi as the defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).

3 On August 22, 2023, based on the parties’ consent, the case was transferred to this Court to conduct all proceedings pursuant to 28 U.S.C. § 636(c). Order Transferring, ECF No. 10. Court finds that Plaintiff’s counsel’s request for fees is reasonable, and Defendant does not oppose the request. ECF No. 22. Therefore, Plaintiff’s motion should be

granted. I. LEGAL STANDARD FOR THE EAJA The EAJA permits the recovery of attorney’s fees in proceedings for judicial

review of an agency’s action. 28 U.S.C. § 2412(d)(1)(A). The purpose is to “ensure adequate representation of those who need it and to minimize the costs of this representation to taxpayers.” Day v. Comm’r Soc. Sec. Admin., No. 6:16-CV-00210, 2017 WL 4417682, at *1 (E.D. Tex. Oct. 31, 2017); see Murkeldove v. Astrue, 635

F.3d 784, 793 (5th Cir. 2011) (purpose is to eliminate the financial disincentive for an average person to challenge unreasonable government actions). In a civil action brought against the United States, the claimant is entitled to

attorney’s fees under the EAJA when the following elements are met: (1) the claimant is the prevailing party, (2) the claimant timely files a fee application, (3) the Court finds the position of the Government was not substantially justified, and (4) no special circumstances make the award unjust. Reese v. Saul, No. 4:19-CV-27872,

2021 WL 2188686, at *1 (S.D. Tex. Apr. 1, 2021) (citing 28 U.S.C. § 2412(d)(1)(A)- (B)). The Court previously found that the ALJ failed to properly evaluate the

severity of Plaintiff’s mental limitations at Step Two in making her RFC determination. ECF No. 20. The claimant is a prevailing party when the district court remands a social security action under sentence four of 42 U.S.C. § 405(g).4 Shalala

v. Shaefer, 509 U.S. 292, 299-301 (1993); Mathews v. Berryhill, No. 4:18-CV- 04795, 2020 WL 242487, at *1 (S.D. Tex. Jan. 16, 2020). Thus, Plaintiff is the prevailing party, and the government’s position was not substantially justified. No special circumstances make the award of fees unjust. 5

II. ANALYSIS Plaintiff’s counsel seeks a fee award of $8,382.926 in attorney’s fees and $402.00 in costs from filing the complaint. ECF No. 22. He submitted evidence

4 “The court shall have power to enter, upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing the decision of the Commissioner of Social Security, with or without remanding the case for a rehearing.” 42 U.S.C. § 405(g). 5 After the district court renders judgment, a party has 30 days from the time that the judgment becomes final to seek an EAJA award. The district court’s judgment becomes final when it can no longer be appealed. 28 U.S.C. § 2412(d)(2)(G). In suits in which a federal officer is a party, the time for appeal does not end until 60 days after the entry of a Rule 58 judgment. Freeman v. Shalala, 2 F.3d 552, 554 (5th Cir. 1993). Thus, a party has 30 days after this 60-day period to seek an EAJA award of fees. In this case, the Court issued a judgment on June 26, 2024, ECF No. 21, which became final sixty days later, on August 25, 2024. Plaintiff had thirty days from August 25, 2024, to file his motion for attorney’s fees. Plaintiff filed his motion on September 25, 2024, one day after the thirty-day period. ECF No. 22. However, a district court held that a Social Security claimant’s request for attorney’s fees should be granted when unopposed, even if one day late. Giles v. Comm’r of Soc. Sec., No. 8:22-cv-1035-DNF, 2023 WL 7385806, at *1-2 (M.D. Fla. Nov. 8, 2023). 6 The itemized statement of hours proposed rates of $240.00/hour (attorney) and $100.00/hour (paralegal), resulting in an initial figure of $9,312.00. ECF No. 22-1. However, in Footnote 1 of ECF No. 22, Plaintiff indicates that “[a]fter consultation between the parties [Plaintiff’s attorney] …agreed to a reduction in time for a total request of $8,382.92.” This reduction demonstrates good faith. Angela C. v. Kijakazi, No. 4:22-CV-0904, 2023 WL 4551207, at *1 n.5 (S.D. Tex. June 28, 2023) (“Plaintiff’s attorney actually worked 42.7 hours on the case but seeks compensation for only 37 hours as an exercise of good faith.”). supporting an hourly rate of $100 for 4.8 hours of paralegal hours worked in 2023 and 2024, and $240.00 for 36.8 attorney hours worked in 2023 and 2024. ECF No.

22-1. The Commissioner does not object to the hours expended or the rate requested.7 ECF No. 22. Nonetheless, the Court must determine whether the fee is reasonable,

requiring an examination of the hours worked and the rate sought. Matthews, 2020 WL 242487, at *2 (citing Chargois v. Barnhart, 454 F. Supp.2d 631, 634 (E.D. Tex. 2006)). Typically, in Social Security cases, fee applications range from twenty to forty hours. Id.8 Plaintiff’s counsel claims 36.8 hours,9 which is within the typical

range of hours for this type of case. Counsel’s hourly rate is higher than the statutory rate of $125,10 requiring a finding that the increase in the cost of living or a special factor justifies a higher fee.

See 28 U.S.C. § 2412(d)(2)(A)(ii). The court has wide discretion in calculating any

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