Sanders 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. The court awarded $11,000 in fees and $400 in costs following a sentence-four remand in the Social Security case. Payment is to be made to the plaintiff, subject to any federal debt offset, with direct payment to plaintiff’s counsel if no offset applies.

Holdings

1. Plaintiff was entitled to an EAJA award because he was the prevailing party following a sentence-four remand, timely filed his fee application, the government did not establish that its position was substantially justified, and no special circumstances made an award unjust.
2. The requested $11,000 EAJA fee award was reasonable and commensurate with the work required in the case.
3. Plaintiff was entitled to recover $400 in costs under the EAJA and 28 U.S.C. § 1920.
4. The fee award was payable to Plaintiff, but if the Department of the Treasury determined that Plaintiff owed no federal debt, the government was required to pay the fees, expenses, and costs directly to Plaintiff's counsel pursuant to the stipulation.

Questions Presented

1. Whether Plaintiff was entitled to attorney fees under the Equal Access to Justice Act after obtaining a sentence-four remand and judgment.
2. Whether the requested $11,000 in attorney fees was reasonable.
3. Whether Plaintiff was entitled to recover $400 in litigation costs under the EAJA and 28 U.S.C. § 1920.
4. Whether payment of the award was subject to Treasury Offset Program deductions and, if not, could be made directly to Plaintiff's counsel.

Disposition

other