Antonia Estorga Coleman v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California granted the parties’ stipulated motion for an award of attorney’s fees under the Equal Access to Justice Act. Following a sentence-four remand in a Social Security case, the court awarded Plaintiff $1,856.04 in attorney’s fees and expenses, 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 for purposes of seeking EAJA fees.
2. The Court awarded Plaintiff $1,856.04 in attorney fees and expenses under the EAJA because the government did not show that its position was substantially justified and no special circumstances made the award unjust.
3. The award is payable to Plaintiff as the prevailing party, but may be paid to Plaintiff’s counsel in accordance with the assignment of fees if the Treasury determines that Plaintiff owes no federal debt; the award remains subject to any applicable Treasury Offset Program offset.

Questions Presented

1. Whether Plaintiff was a prevailing party eligible for attorney fees under the Equal Access to Justice Act after obtaining a sentence-four remand under 42 U.S.C. § 405(g).
2. Whether the stipulated amount of $1,856.04 in attorney fees and expenses should be awarded under the EAJA.
3. Whether the award was subject to offsets under the Treasury Offset Program and, if not, could be paid to Plaintiff’s counsel under the assignment of fees.

Disposition

other