Yueh v. Kijakazi

CourtDistrict Court, N.D. California
DecidedAugust 6, 2025
Docket3:23-cv-00824
StatusUnknown

This text of Yueh v. Kijakazi (Yueh v. Kijakazi) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Yueh v. Kijakazi, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 JULIENNE YUEH, Case No. 23-cv-00824-AMO

8 Plaintiff, ORDER RE ATTORNEY FEES v. 9 Re: Dkt. No. 19 10 LELAND DUDEK, Defendant. 11

12 13 After Plaintiff Julienne Yueh brought this action for review of the Commissioner of Social 14 Security’s decision to deny benefits, the Court remanded the case on stipulation of the parties, and 15 the Commissioner issued a favorable decision. Her attorney, Katherine Siegfried, now seeks 16 $17,480 in attorney fees under Section 206(b) of the Social Security Act, 42 U.S.C. § 406(b). 17 ECF No. 19. For the reasons set forth below, the motion is GRANTED IN PART AND 18 DENIED IN PART. 19 I. RELEVANT FACTS AND PROCEDURAL HISTORY 20 After Ms. Yueh applied for disability benefits, her application was denied initially, at 21 reconsideration, after an initial administrative hearing, and at the Appeals Council. This action for 22 judicial review was then filed pursuant to 42 U.S.C. § 405(g) on Ms. Yueh’s behalf. ECF No. 1. 23 Defendant stipulated to a voluntary remand, and this Court issued an order remanding for further 24 proceedings. ECF No. 15. The Court subsequently granted the parties’ stipulation for attorney 25 fees under the Equal Access to Justice Act (“EAJA”), 28 U.S.C. § 2412, in the amount of $1,541. 26 ECF No. 18. 27 On remand, the Commissioner granted Plaintiff’s application and awarded ongoing 1 fee agreement, Plaintiff agreed to pay counsel up to 25% of any past-due benefits resulting from a 2 favorable disability decision. ECF No. 19, Ex. 4. 3 In the Notice of Award, Plaintiff was informed that 25% of the past-due disability benefits 4 amounted to $24,680.18, and that this amount was set aside to pay her attorney fees. ECF No. 19, 5 Ex. 3. 6 II. LEGAL STANDARD 7 Attorneys handling Social Security proceedings may seek fees for their work under both 8 the EAJA and the Social Security Act. While the government pays an award pursuant to the 9 EAJA, an award pursuant to Section 406 of the Social Security Act is paid out of a successful 10 claimant’s past-due benefits. See 42 U.S.C. § 406(b)(1)(A); Russell v. Sullivan, 930 F.2d 1443, 11 1446 (9th Cir. 1991), abrogated on other grounds by Sorensen v. Mink, 239 F.3d 1140, 1149 (9th 12 Cir. 2001). Section 406(b)(1) provides that a federal court that “renders a judgment favorable to a 13 claimant . . . who was represented before the court by an attorney” may grant the attorney “a 14 reasonable fee for such representation, not in excess of 25 percent of the total of the past-due 15 benefits to which the claimant is entitled by reason of such judgment.” In passing Section 406, 16 Congress sought to protect attorneys from the nonpayment of fees, while also shielding clients 17 from unfairly large fees. Gisbrecht v. Barnhart, 535 U.S. 789, 805 (2002). 18 The Supreme Court in Gisbrecht explained that Section 406(b) is meant “to control, not to 19 displace, [contingency] fee agreements between Social Security benefits claimants and their 20 counsel.” 535 U.S. at 793. Even if a fee request under Section 406(b) is within the 25 percent 21 statutory limit, the attorney bears the burden of showing that the fee sought is reasonable, and the 22 court is responsible for serving as an “independent check” to ensure the reasonableness of the fee. 23 Id. at 807. Following Gisbrecht, the Ninth Circuit has instructed that a Section 406(b) fee request 24 should be assessed by “looking first to the contingent-fee agreement, then testing it for 25 reasonableness.” Crawford v. Astrue, 586 F.3d 1142, 1149 (9th Cir. 2009) (en banc) (quoting 26 Gisbrecht, 535 U.S. at 808). The court should consider “the character of the representation and 27 the results the representative achieved,” and determine “whether the amount [of fees specified in 1 delay, or benefits that are not in proportion to the time spent on the case.” Id. at 1151. The 2 reasonableness determination is not governed by the lodestar method, because “[t]he lodestar 3 method under-compensates attorneys for the risk they assume in representing [social security] 4 claimants and ordinarily produces remarkably smaller fees than would be produced by starting 5 with the contingent-fee agreement.” Id. at 1150. 6 Additionally, a Section 406(b) fee award is offset by any award of EAJA fees. Thus, if the 7 court awards fees under both the EAJA and Section 406(b), “the claimant’s attorney must refun[d] 8 to the claimant the amount of the smaller fee.” Gisbrecht, 535 U.S. at 796 (internal quotations and 9 citation omitted; modification in original). 10 III. DISCUSSION 11 The Court finds counsel has met her burden to demonstrate that the requested fees are 12 reasonable but only to an extent. As noted above, Plaintiff entered into a contingent fee agreement 13 providing for a 25% fee, which is consistent with the statutory cap. There is no evidence that 14 Siegfried’s performance was substandard; to the contrary, counsel’s representation resulted in 15 Plaintiff receiving $98,720.70 in past-due benefits – an excellent result. See Matos v. Saul, No. 16 19-cv-02505-TSH, 2021 WL 1405467, at *2 (N.D. Cal. Apr. 14, 2021) (awarding 25%, equaling 17 $21,474.90 for 53.5 hours of work at an effective hourly rate of $401, under contingent fee 18 agreement where plaintiff received $109,899.60 in benefits upon post-summary judgment 19 remand); Khlopoff v. Saul, No. 18-cv-03149-TSH, 2020 WL 7043878, at *2 (N.D. Cal. Dec. 1, 20 2020) (awarding 25% under contingent fee agreement where plaintiff received $73,209.00 in 21 benefits upon post-summary judgment remand). 22 Plaintiff’s counsel states her non-contingency based hourly rate for appellate cases (not 23 related to Social Security) is currently $500 per hour. ECF No. 19, Ex. 1. She also states she 24 spent 6.55 hours working on this case. Based on the award requested, this would make for an 25 effective hourly rate of $2,649 per hour, well outside any effective hourly rate approved in the 26 cases Siegfried offers in support of the requested award.1 See, e.g., Crawford, 586 F.3d at 1153 27 1 (approving effective hourly rates of $519, $875, and $902); McCullough v. Berryhill, No. 16-cv- 2 00625-BLF, 2018 WL 6002324, at *2 (N.D. Cal. Nov. 15, 2018) (approving effective hourly rate 3 of $874.72); Harrell v. Berryhill, No. 16-cv-02428-TSH, 2018 WL 4616735, at *4 (N.D. Cal. 4 Sept. 24, 2018) (finding de facto hourly rate of $1,213 reasonable under Gisbrecht); Lopez v. 5 Colvin, No.14-cv-03395-JSC, 2017 WL 168060, at *2 n.2 (N.D. Cal. Jan. 17, 2017) (approving 6 effective hourly rate of $1,131 even though it was “very high” based on its ultimate 7 reasonableness under Crawford factors); Palos v. Colvin, No. CV 15-04261-DTB, 2016 WL 8 5110243, at * 2 (C.D. Cal. Sept. 20, 2016) (approving fees in the amount of $15,000, making for 9 an effective hourly rate of $1,546.39 for 9.7 hours of work, where it was “not so inordinately large 10 in comparison with the number of hours spent by Counsel on the case that it would represent a 11 windfall to Counsel.”); Michelle H. v. Berryhill, No. 18-cv-2328-JLS (RNB), 2022 WL 1138146, 12 at *4 (S.D.

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Related

Gisbrecht v. Barnhart
535 U.S. 789 (Supreme Court, 2002)
Moreno v. City of Sacramento
534 F.3d 1106 (Ninth Circuit, 2008)
Crawford v. Astrue
586 F.3d 1142 (Ninth Circuit, 2009)
Hearn v. Barnhart
262 F. Supp. 2d 1033 (N.D. California, 2003)

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Yueh v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/yueh-v-kijakazi-cand-2025.