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