Wilson v. O'Malley

CourtDistrict Court, S.D. Florida
DecidedMay 28, 2025
Docket0:24-cv-61554
StatusUnknown

This text of Wilson v. O'Malley (Wilson v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wilson v. O'Malley, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 24-CV-61554-ELFENBEIN

STEVE W. WILSON,

Plaintiff,

v.

MARTIN J O'MALLEY, COMMISSIONER OF SOCIAL SECURITY,

Defendant. /

ORDER ON UNOPPOSED MOTION TO VACATE AND REENTER JUDGMENT

THIS CAUSE is before the Court on Plaintiff’s Unopposed Motion to Vacate and Reenter Judgment to set aside the Court’s Order on Plaintiff’s Unopposed Motion for Attorney’s Fees under the Equal Access to Justice Act (“EAJA”), 28 U.S.C.A. § 2412(d) (the “Motion to Vacate”), ECF No. [20]. For the reasons explained below, the Motion to Vacate, ECF No. [20], is GRANTED. On April 2, 2025, Plaintiff filed his Unopposed Motion for Attorney’s Fees under the EAJA, 28 U.S.C.A. § 2412(d) (the “Motion for Fees”), ECF No. [18]. In the Motion for Fees, Plaintiff asserted that Defendant consents to the requested relief and does not object to the time and fees requested in the Motion for Fees. See ECF No. [18] at 1, 5. On April 9, 2025, the Court denied the Motion for Fees as untimely under the EAJA (the “Order”). See ECF No. [19] (citing 28 U.S.C. § 2412(d)(1)(B)). On April 10, 2025, Plaintiff filed his Motion to Vacate the Order requesting that the Court: “(1) vacate the Order denying Plaintiff’s Motion for Attorney’s Fees under the EAJA (ECF 19)[;] and (2) reenter judgment with an Order approving Plaintiff’s Motion for Attorney’s Fees under the EAJA.” See ECF No. [20] at 2. In the Motion to Vacate, Plaintiff explained the Motion was not timely filed as a result of a protracted meet-and-confer process with the Defendant. Upon review and in light of Defendant’s express non-opposition to both the Motion for Fees and Motion to Vacate, allowing filing out-of-time, the Court grants Plaintiff’s request. “A

court should grant a Social Security claimant’s request for attorney’s fees when it is unopposed.” Giles v. Comm’r of Soc. Sec., No. 22-CV-1035-DNF, 2023 WL 7385806, at *1–2 (M.D. Fla. Nov. 8, 2023) (quoting Miller v. Berryhill, No. 17-CV-1470-T-AAS, 2019 WL 1586733, at *1 (M.D. Fla. Apr. 12, 2019)). Therefore, the Court will award attorney’s fees under EAJA on that basis and the Court finds as follows: I. LEGAL STANDARDS A. Entitlement to Costs and Fees Under the Equal Access to Justice Act Under the Equal Access to Justice Act, the Court may award “a judgment for costs” to “the prevailing party in any civil action brought” against “any agency or any official of the United States acting in his or her official capacity.” See 28 U.S.C. § 2412(a)(1). The Court may also

“award reasonable fees and expenses of attorneys, in addition to the costs which may be awarded pursuant to subsection (a), to the prevailing party in any civil action brought” against “any agency or any official of the United States acting in his or her official capacity.” See id. § 2412(b); Pub. L. No. 96-481 §§ 201, 204, 94 Stat. 2321 (1980). In fact, the authorizing statute provides that “a court shall award to a prevailing party other than the United States fees and other expenses, in addition to any costs awarded pursuant to subsection (a), incurred by that party in any civil action (other than cases sounding in tort), including proceedings for judicial review of agency action, brought . . . against the United States in any court having jurisdiction of that action, unless the court finds that the position of the United States was substantially justified or that special circumstances make an award unjust.” See 28 U.S.C. § 2412(d)(1)(A) (emphasis added). To receive costs and fees, a party “shall, within thirty days of final judgment in the action, submit to the court an application for fees and other expenses which shows that the party is a prevailing party and is eligible to receive an award under this subsection, and the amount sought,

including an itemized statement from any attorney or expert witness representing or appearing in behalf of the party stating the actual time expended and the rate at which fees and other expenses were computed. The party shall also allege that the position of the United States was not substantially justified.” See id. § 2412(d)(1)(B). A party is “prevailing” in a Social Security appeal if he wins “a remand order pursuant to sentence four of [42 U.S.C.] § 405(g).” See Shalala v. Schaefer, 509 U.S. 292, 300 (1993). A party is “eligible to receive an award,” if his “net worth” does “not exceed $2,000,000 at the time the civil action was filed.” See 28 U.S.C. § 2412(d)(2)(B). And the “‘position of the United States’ means, in addition to the position taken by the United States in the civil action, the action or failure to act by the agency upon which the civil action is based.” See id. § 2412(d)(2)(D). “Whether or

not the position of the United States was substantially justified shall be determined on the basis of the record (including the record with respect to the action or failure to act by the agency upon which the civil action is based) which is made in the civil action for which fees and other expenses are sought.” See id. § 2412(d)(1)(B). The Supreme Court has held that Equal Access to Justice attorney’s fee awards are payable not to the lawyer but “to the litigant,” which means that any such award is subject to “a federal administrative offset if the litigant has outstanding federal debts.” See Astrue v. Ratliff, 560 U.S. 586, 593, 596 (2010); Rodriguez, 2023 WL 3852275, at *4. The litigant may, however, assign his “rights in the fees award to the attorney,” see Astrue, 560 U.S. at 597, as long as the assignment either complies with the Anti-Assignment Act, 31 U.S.C. § 3727(b), see Rodriguez, 2023 WL 3852275, at *4, or the government has waived the Anti-Assignment Act’s requirements, see Arthur Pew Const. Co. v. Lipscomb, 965 F.2d 1559, 1576 (11th Cir. 1992). If the litigant “does not owe a debt to the government and assigns the right to receive the fees to the attorney,” the government

will pay the award to the attorney directly. See Astrue, 560 U.S. at 597 (quotation marks omitted). B. Calculating Attorney’s Fee Awards Generally To calculate attorney’s fee awards, courts generally use the “lodestar” method. See Norman v. Hous. Auth. of City of Montgomery, 836 F.2d 1292, 1299 (11th Cir. 1988); Inj. Treatment Ctr., 2022 WL 17325834, at *2. “The most useful starting point for determining the amount of a reasonable fee” using the lodestar method “is the number of hours reasonably expended on the litigation multiplied by a reasonable hourly rate. This calculation provides an objective basis on which to make an initial estimate of the value of a lawyer’s services.” See Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); ACLU of Ga. v. Barnes, 168 F.3d 423, 427 (11th Cir. 1999) (noting that the lodestar is “properly calculated by multiplying the number of hours

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Wilson v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilson-v-omalley-flsd-2025.