CLARK v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER

Clark v. Soc. Sec. Admin. Comm'r · United States District Court, District of Maine · May 9, 2025 · No. 2:22-cv-00103

Summary

This memorandum and order from the United States District Court for the District of Maine resolves a motion for attorney fees under 42 U.S.C. § 406(b)(1) arising from a Social Security disability claim. The court evaluates the reasonableness of the requested $22,314.00 contingent fee, finds it compliant with statutory limits and prior case law, and notes the Commissioner's lack of opposition. The motion is granted, authorizing payment from the plaintiff's past-due benefits subject to the attorney refunding a previously awarded Equal Access to Justice Act fee.

Court
United States District Court, District of Maine
Writing for the Court
Stacey D. Neumann
Jurisdiction
United States District Court, District of Maine
Decision date
May 9, 2025
Docket number
2:22-cv-00103
Procedural posture
Plaintiff moved for attorney fees under 42 U.S.C. §406(b) after obtaining a favorable judgment on her disability claim.
Precedential value
nonprecedential
Disposition
approved

Topics

judicial review of agency actionadministrative lawremedies

Practice areas

administrative lawcivil procedure

Questions Presented

  1. Whether the $22,314 fee request complies with 42 U.S.C. §406(b) and does not exceed the 25% statutory limit and is reasonable.

Holdings

  1. The court granted the motion, finding the fee permissible under §406(b) because it conforms to the contingent fee agreement, does not exceed the 25% limit, and is reasonable.

Key quotations

Accordingly, the Motion for Award of Attorney Fees is GRANTED and the Court ORDERS that a fee award in the amount of $22,314 be paid to Attorney Fenner from Plaintiff’s past-due benefits in accordance with Social Security Administration policy, subject to the requirement that Attorney Fenner pay Plaintiff $5,888, the sum earlier awarded to Attorney Fenner pursuant to the Equal Access to Justice Act. (end)

Factual background

Plaintiff entered a contingent fee agreement with Attorney Riley Fenner for 25% of any past‑due benefits awarded. The Social Security Administration withheld the same percentage from Plaintiff’s award, and the district court previously awarded $5,888 to the attorney under the EAJA, which the attorney must refund.

Procedural history

Plaintiff obtained a judgment awarding past‑due Social Security Disability benefits. The Social Security Appeals Council remanded for a hearing, resulting in a favorable judgment. Plaintiff then filed a motion for attorney fees under §406(b). The district court considered the motion and issued this order.

Court Document

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