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Golden, Jr. v. Commissioner of Social Security
6:22-cv-06252
W.D.N.Y.
Jun 10, 2025
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Background

  • Plaintiff Robert James G., Jr. brought an action contesting the denial of his claim for Social Security benefits.
  • On February 7, 2025, the court granted plaintiff’s motion for judgment on the pleadings and remanded the matter to the Commissioner.
  • Plaintiff then sought attorney’s fees under the Equal Access to Justice Act (“EAJA”), arguing he was the prevailing party.
  • Plaintiff and the Commissioner agreed to an attorney’s fee amount of $8,043.93, reflecting an adjusted hourly rate due to inflation.
  • The court reviewed the fee stipulation to independently assess its reasonableness.
  • Plaintiff assigned his right to EAJA fees to his counsel, subject to requirements regarding potential federal debts.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Plaintiff's Status as Prevailing Party under EAJA Plaintiff prevailed by obtaining a remand. Not taken or not contested. Plaintiff is a prevailing party eligible for EAJA fees.
Reasonableness of Attorney Fees Amount Hours and rate are reasonable; CPI-adjusted. Stipulated to amount. The fee amount and hours are reasonable and appropriate.
Payment Assignment to Counsel Fee can be paid to counsel via assignment. No opposition noted. Fee can be paid to counsel unless a federal debt offsets, then to plaintiff direct.
Government Justification for Position Government failed to justify its position. No substantial justification. No evidence that government position was substantially justified; fees appropriate.

Key Cases Cited

  • Shalala v. Schaefer, 509 U.S. 292 (remand under these circumstances makes plaintiff a prevailing party for EAJA purposes)
  • Astrue v. Ratliff, 560 U.S. 586 (EAJA fee awards are payable to litigants and subject to offset for federal debts)
  • Eames v. Bowen, 864 F.2d 251 (government bears burden to show its position was substantially justified)
Read the full case

Case Details

Case Name: Golden, Jr. v. Commissioner of Social Security
Court Name: District Court, W.D. New York
Date Published: Jun 10, 2025
Citation: 6:22-cv-06252
Docket Number: 6:22-cv-06252
Court Abbreviation: W.D.N.Y.