Summary
The United States District Court for the Eastern District of California granted the parties’ stipulated request for an award of attorney fees under the Equal Access to Justice Act. The court awarded $6,300 to Plaintiff Angel Cabral as the prevailing party following a sentence-four remand in the Social Security case. Payment is to be made payable to Plaintiff, with direct payment to counsel if the Treasury Department determines that Plaintiff owes no federal debt.
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Practice areas
Questions Presented
- Whether Plaintiff qualified as a prevailing party and timely sought attorney fees under the Equal Access to Justice Act after obtaining a sentence-four remand.
- Whether the government's position was substantially justified or special circumstances made an EAJA fee award unjust.
- Whether the requested $6,300 attorney-fee award was reasonable.
- Whether the award should be payable to Plaintiff, with direct payment to counsel if no federal debt required an offset.
Holdings
- A party who obtains a sentence-four remand under 42 U.S.C. § 405(g) is a prevailing party for purposes of the EAJA, and Plaintiff's fee request was timely.
- The court must award EAJA fees to a prevailing party where the statutory requirements are met unless the government's position was substantially justified or special circumstances would make an award unjust; here, Plaintiff was entitled to an award because the government did not establish either exception and did not oppose the request.
- The requested $6,300 EAJA fee award was reasonable and commensurate with the work required by the size of the administrative record, the summary-judgment briefing, and the favorable result obtained.
- The EAJA award is payable to Plaintiff and remains subject to any Treasury Offset Program offset; if the Treasury determines Plaintiff owes no federal debt, the government must cause payment to be made directly to Plaintiff's counsel under the stipulation.
Key quotations
“Under the EAJA, a court shall award attorney fees to the prevailing party unless it finds the government’s position was “substantially justified or that special circumstances make such an award unjust.”” (at 2)
“Accordingly, it is HEREBY ORDERED:” (at 3)
Factual background
Plaintiff prevailed on a motion for summary judgment in a Social Security action, obtaining a sentence-four remand for further proceedings. The administrative record was approximately 641 pages, and counsel prepared a summary-judgment motion and reply. Plaintiff requested $6,300 in EAJA fees, and the Commissioner did not oppose the request.
Procedural history
On March 13, 2025, the court granted Plaintiff's motion for summary judgment, remanded the case to the Commissioner for further proceedings under sentence four of 42 U.S.C. § 405(g), and entered judgment. Plaintiff filed a stipulated request for $6,300 in EAJA attorney fees on June 10, 2025. The court granted the request and directed payment to Plaintiff, subject to the parties' stipulation and any Treasury Offset Program offset.
Remand instructions
The Commissioner must pay Plaintiff $6,300 in attorney fees pursuant to the parties' stipulation. Payment is to be made payable to Plaintiff, but if the Department of the Treasury determines that Plaintiff owes no federal debt, the government must cause payment of fees, expenses, and costs to be made directly to Plaintiff's counsel.