Erram v. Commissioner of Social Security, 2:21-cv-02368

Plaintiff Satyajit Vilas Erram brought a Social Security-related civil action in the Eastern District of California (Case No. 2:21-cv-02368-EFB).
Parties filed a stipulation resolving Plaintiff’s request for attorney fees under the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412(d), and costs under 28 U.S.C. § 1920.
The stipulated award: $1,000 in EAJA fees and $627 in taxable costs.
The stipulation recognized Plaintiff’s assignment of EAJA fees to Chermol & Fishman, LLC and acknowledged the Treasury Offset Program could reduce payment under Astrue v. Ratliff.
Payment was to be made to Plaintiff; if the Treasury determined Plaintiff owed no federal debt, payment would be made directly to counsel per the assignment.
The stipulation included a release barring further EAJA-fee claims related to this action; the court approved the stipulation and denied Plaintiff’s separately filed EAJA fee motion as moot (order dated July 18, 2022).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether to award EAJA fees and taxable costs	Entitled to EAJA fees and costs; filed motion for fees	Agreed to stipulated amounts and terms, subject to offset rules	Court approved stipulated award: $1,000 (EAJA) and $627 (costs); motion denied as moot
Treatment of Plaintiff’s assignment of EAJA fees to counsel	Assignment to Chermol & Fishman should be honored	Payment is to plaintiff; Treasury Offset may reduce or redirect payment per federal rules	Payment ordered to plaintiff; if no federal debt, Treasury will pay counsel per assignment; subject to offset review
Effect of stipulation on future claims	Stipulation resolves fee claim	Stipulation is a compromise and not admission of liability	Court accepted stipulation; payment constitutes complete release and bar of further EAJA-fee claims

Astrue v. Ratliff, 560 U.S. 586 (2010) (Treasury Offset may be applied to EAJA fee awards and assignment to counsel does not negate offset)