Summary
The United States District Court for the District of Puerto Rico grants the plaintiff’s unopposed motion for attorney’s fees under the Equal Access to Justice Act. The court awards $3,425.02 in attorney’s fees and $405.00 in costs following a sentence-four remand of the plaintiff’s disability insurance benefits claim to the Social Security Administration.
Topics
Practice areas
Questions Presented
- Whether Plaintiff satisfied the statutory requirements for an award of attorney's fees and costs under the Equal Access to Justice Act after obtaining a sentence-four remand in a Social Security case.
- Whether the court should award the parties' agreed amount of $3,425.02 in attorney's fees and $405.00 in costs.
Holdings
- An EAJA fee award requires that the claimant be a prevailing party, that the Government's position was not substantially justified, that no special circumstances make an award unjust, and that the fee application be timely submitted with the required itemized statement.
- Plaintiff was entitled to an award of $3,425.02 in attorney's fees and $405.00 in costs, for a total of $3,830.02.
Key quotations
“Eligibility for a fee award in any civil action under the EAJA requires: (1) that the claimant be a “prevailing party”; (2) that the Government’s position was not “substantially justified”; (3) that no special circumstances make an award unjust; and (4) that any fee application be submitted to the court within 30 days of final judgment, supported by an itemized statement as required by 28 U.S.C. § 2412(d)(1)(B).”
Factual background
Awilda M.Q. applied for disability insurance benefits, but the Commissioner issued a final decision denying her application. The Commissioner later sought reversal and remand for further administrative proceedings, and the district court entered judgment remanding the claim. Plaintiff requested EAJA fees and costs, and the parties agreed on the amount to be awarded.
Procedural history
Plaintiff filed a complaint challenging the denial of disability insurance benefits. The Commissioner requested reversal and remand for further administrative proceedings, which the court granted under sentence four of 42 U.S.C. § 405(g). Plaintiff then filed an unopposed EAJA fee motion, and the parties agreed on the amount of fees and costs.
Remand instructions
The court previously remanded Plaintiff's disability insurance benefits claim to the Social Security Administration for further administrative proceedings pursuant to sentence four of 42 U.S.C. § 405(g). This order itself grants EAJA fees and costs.