Summary
The United States District Court for the Eastern District of California granted the parties’ stipulated request for $6,300 in attorney’s fees under the Equal Access to Justice Act after remanding the Social Security action for further proceedings under sentence four of 42 U.S.C. § 405(g). The court denied as moot the plaintiff’s earlier fee motion and directed that payment be made to the plaintiff, subject to Treasury Offset Program requirements and potential direct payment to counsel.
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Practice areas
Questions Presented
- Whether Plaintiff was entitled to attorney fees under the Equal Access to Justice Act after obtaining a sentence-four remand.
- Whether the stipulated request for $6,300 in EAJA fees was reasonable.
- Whether payment of the EAJA award should be subject to Treasury Offset Program offsets and made payable to Plaintiff, with direct payment to counsel if no federal debt existed.
Holdings
- A party who obtains a sentence-four remand under 42 U.S.C. § 405(g) is a prevailing party eligible to seek EAJA fees.
- The court shall award attorney fees to a prevailing party under the EAJA when the application is timely, unless the government's position was substantially justified or special circumstances would make an award unjust; here, Plaintiff satisfied those requirements.
- The requested $6,300 EAJA fee was reasonable and commensurate with the work performed in reviewing the administrative record and preparing the summary-judgment briefing.
- EAJA fees, expenses, and costs are subject to any applicable Treasury Offset Program offsets; if no federal debt exists, payment may be made directly to Plaintiff's counsel under the terms of 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)
“EAJA fees, expenses, and costs are subject to any offsets allowed under the Treasury Offset Program (“TOP”), as discussed in Astrue v. Ratliff, 560 U.S. 586 (2010).” (at 3)
Factual background
Plaintiff prevailed on a motion for summary judgment in a Social Security action and obtained a sentence-four remand for further proceedings. Plaintiff requested $6,300 in EAJA fees for counsel's work, which included reviewing an approximately 713-page administrative record and preparing a summary-judgment motion and reply. The Commissioner did not oppose the stipulated request, and the court found that the government's position was not substantially justified and that no special circumstances made an award unjust.
Procedural history
On September 19, 2025, the court granted Plaintiff's motion for summary judgment, remanded the action to the Commissioner pursuant to sentence four of 42 U.S.C. § 405(g), and entered judgment the same day. Plaintiff subsequently moved for EAJA fees and then filed a stipulated request for $6,300 in attorney fees. The court denied the prior fee motion as moot and granted the stipulated EAJA request.