Hamilton v. Secretary of Health and Human Services, 21-1012V

Currin M. Hamilton filed a compensation claim under the National Vaccine Injury Compensation Program, alleging a shoulder injury from a Tetanus diphtheria vaccine administered in 2019.
On June 20, 2024, the Special Master awarded compensation to Hamilton based on the respondent's proffer.
Hamilton then applied for attorneys’ fees and costs totaling $27,938.90, which included $27,536.90 in fees and $402.00 in costs.
The government did not contest eligibility for a fee award but left the amount to the court’s discretion.
The Special Master reviewed the hourly rates and billing records, reducing certain fee amounts where the attorney was not admitted to practice before the Court.
The court found the claimed costs reasonable and awarded a reduced total of $26,264.40 in fees and costs.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Reasonableness of Hourly Rates and Fees	Requested rates were reasonable for work performed	Left to court's discretion	Reduced rate for non-admitted attorney; others OK
Recovery of Attorney’s Fees and Costs	Full amount claimed should be awarded	Did not object to recovery	Awarded most, minus reduction for non-admitted atty
Admissibility of Attorney for Fee Purposes	Non-admitted attorney’s rate should be honored	Not argued	Non-admitted attorney compensated at lower rate
Adequacy of Documentation for Costs	All costs documented and justified	No specific objections	All requested litigation costs awarded

Saxton v. Sec’y of Health & Human Servs., 3 F.3d 1517 (Fed. Cir. 1993) (special master has discretion to reduce excessive, redundant, or unnecessary fee hours)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (fees should exclude unreasonable hours and courts have discretion in determining reasonableness)
Savin v. Sec’y of Health & Human Servs., 85 Fed. Cl. 313 (2008) (fee requests must be supported by adequate documentation)