Summary
The United States District Court for the District of Puerto Rico denied Plaintiff Benigno N.’s motion for attorney’s fees under the Equal Access to Justice Act. The court held that the Commissioner’s position was substantially justified because the due-process issue concerning the Social Security Administration’s fraud-redetermination procedures was novel, unsettled, and subject to conflicting persuasive authority. The court also found that the submitted time records were inadequately detailed and appeared substantially duplicated from another case.
Court
United States District Court for the District of Puerto Rico
Jurisdiction
United States District Court for the District of Puerto Rico
Decision date
April 30, 2026
Docket number
Civil No. 23-1226 (GLS)
Disposition
other
Questions Presented
- Whether Plaintiff was entitled to attorney's fees under the Equal Access to Justice Act despite the Commissioner's position being substantially justified in light of the novelty and unsettled nature of the due-process issue.
- Whether Plaintiff satisfied the EAJA requirement to submit an itemized statement of actual time expended supported by detailed contemporaneous records.
Holdings
- Plaintiff did not satisfy 28 U.S.C. § 2412(d)(1)(B) because the nearly identical time entries copied from another case and the aggregated, undated research entry prevented the court and the Commissioner from determining whether the claimed time accurately reflected work performed in this case or whether the hours were reasonable.
- The Commissioner's position was substantially justified because the due-process issue was novel, lacked controlling circuit precedent, and was subject to conflicting persuasive decisions within the district when the Commissioner advanced his position.
Court Document
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