Pat Darwin Caudill v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California granted the parties’ stipulated request for attorney’s fees and costs under the Equal Access to Justice Act and 28 U.S.C. § 1920. The court awarded $7,700.00 in attorney’s fees and $402.00 in costs to the plaintiff, subject to Treasury Offset Program requirements and potential direct payment to plaintiff’s counsel.

Holdings

1. A party who obtains a sentence-four remand under 42 U.S.C. § 405(g) is a prevailing party for purposes of the EAJA.
2. Plaintiff was entitled to an EAJA attorney-fee award because he prevailed, timely sought fees, the government did not establish substantial justification, and no special circumstances made an award unjust.
3. The stipulated request for $7,700 in EAJA attorney fees was reasonable and should be awarded.
4. Plaintiff was entitled to the stipulated $402 award of costs under 28 U.S.C. §§ 2412(a)(1) and 1920.
5. EAJA fees, expenses, and costs remain subject to permissible Treasury Offset Program deductions; if no federal debt offset applies, payment may be made directly to Plaintiff's counsel as provided in the stipulation.

Questions Presented

1. Whether Plaintiff qualified as a prevailing party entitled to attorney fees under the Equal Access to Justice Act after obtaining a sentence-four remand.
2. Whether the government's position was substantially justified or special circumstances made an EAJA fee award unjust.
3. Whether Plaintiff was entitled to the stipulated $7,700 attorney-fee award and $402 cost award.
4. Whether the fee, expense, and cost award was subject to Treasury Offset Program deductions and conditional direct payment to Plaintiff's counsel.

Disposition

other