Dennise Labrador v. Andrew Saul

Labrador · United States District Court for the Southern District of Texas, Houston Division · February 24, 2026 · No. 4:24-CV-04891

Summary

The United States District Court for the Southern District of Texas adopted a magistrate judge’s Memorandum and Recommendation after finding no clear error and noting that no objections had been filed. The court granted Plaintiff Dennise Labrador’s motion for attorney fees under the Equal Access to Justice Act and awarded $6,807.71, subject to any applicable administrative offset.

Court
United States District Court for the Southern District of Texas, Houston Division
Writing for the Court
Wifred H. Bennett
Jurisdiction
United States District Court for the Southern District of Texas, Houston Division
Decision date
February 24, 2026
Docket number
4:24-CV-04891
Procedural posture
The district court reviewed a magistrate judge's Memorandum and Recommendation on Plaintiff's motion for attorney fees under the Equal Access to Justice Act after the objection deadline expired without objections.
Standard of review
Clear-error review under Federal Rule of Civil Procedure 72(b) because no objections were filed to the magistrate judge's Memorandum and Recommendation.
Precedential value
Unpublished district-court order; precedential status not stated in the opinion.
Parties
Dennise Labrador v. Andrew Saul
Disposition
other

Topics

attorney feescivil procedureremedies

Practice areas

Social SecurityAdministrative lawAttorney's fees

Questions Presented

  1. Whether the magistrate judge's Memorandum and Recommendation should be adopted when no objections were filed and the district court found no clear error.
  2. Whether Plaintiff was entitled to an award of $6,807.71 in attorney's fees under the Equal Access to Justice Act.

Holdings

  1. When no objections are filed to a magistrate judge's Memorandum and Recommendation, the district court reviews the recommendation for clear error; finding no clear error, the court may adopt it in its entirety.
  2. Plaintiff's motion for attorney's fees under the Equal Access to Justice Act was properly granted, and Plaintiff was awarded $6,807.71 in attorney's fees.

Key quotations

Finding no clear error, the Court adopts the Memorandum and Recommendation in its entirety.
Plaintiff is hereby awarded $6,807.71 in attorney’s fees

Factual background

The case arose from Plaintiff's request for attorney fees under the Equal Access to Justice Act. The magistrate judge issued a Memorandum and Recommendation, and Plaintiff's motion for attorney fees was before the district court for review. The district court found no clear error and awarded $6,807.71 in attorney's fees, payable to Plaintiff and mailed to Plaintiff's counsel, subject to any applicable administrative offset for outstanding federal debt.

Procedural history

United States Magistrate Judge Richard W. Bennett issued a Memorandum and Recommendation, identified as Doc. #21. No objections were filed by the deadline. The district court reviewed the recommendation for clear error, adopted it in its entirety, and granted Plaintiff's motion for attorney fees under the Equal Access to Justice Act.

Court Document

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