Carolyn Lett Craig v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California granted the parties’ stipulated request for attorney fees and costs under the Equal Access to Justice Act following a sentence-four remand in a Social Security case. The court awarded $3,735.71 in EAJA attorney fees and $402.00 for the filing fee, subject to any applicable Treasury Offset Program deductions.

Holdings

1. A party who obtains a sentence-four remand under 42 U.S.C. § 405(g) is a prevailing party eligible to seek EAJA fees.
2. The Court awarded EAJA attorney fees because Plaintiff prevailed, timely sought fees, the government did not establish that its position was substantially justified, and no special circumstances made an award unjust.
3. The requested $3,735.71 in EAJA fees was reasonable and commensurate with the work required to review the voluminous administrative record and prepare the summary judgment motion.
4. The Court awarded Plaintiff the $402.00 filing fee as a recoverable cost under 28 U.S.C. §§ 2412(a) and 1920.

Questions Presented

1. Whether Plaintiff was a prevailing party entitled to attorney fees under the Equal Access to Justice Act after a sentence-four remand.
2. Whether the government's position was substantially justified or special circumstances made an EAJA fee award unjust.
3. Whether the requested attorney fees and $402.00 filing fee were reasonable and recoverable as costs.

Disposition

other