Jones v. Colvin, 2:15-cv-00516

Tami Winn Jones filed suit seeking reversal and remand of an ALJ decision denying supplemental security income under Title XVI.
The district court remanded on August 22, 2016, directing the ALJ to further analyze several medical opinions, explain how the RFC addressed mental impairments and obesity, and to ensure age was not used in the RFC determination.
The remand rendered Jones the prevailing party under the EAJA.
Jones moved for EAJA attorney fees of $6,092.00; the Commissioner did not dispute the fee amount but argued her position was substantially justified.
The court found the Commissioner’s position not substantially justified because the ALJ committed legal error by considering the claimant’s age in formulating the RFC and failed to meet required standards for evaluating medical opinions.
The court awarded $6,092.00 in EAJA fees payable to Jones and to be mailed to her counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Commissioner’s position was "substantially justified" for EAJA denial of fees	Jones argued the government lacked substantial justification because the ALJ committed legal error (used age in RFC) and failed to properly evaluate medical opinions	Commissioner argued her position was substantially justified and fees should be denied	Court held the government was not substantially justified and awarded EAJA fees

Hackett v. Barnhart, 475 F.3d 1166 (10th Cir. 2007) (government bears burden to prove substantial justification)
Pierce v. Underwood, 487 U.S. 552 (U.S. 1988) (definition and scope of "substantially justified")
Gatson v. Bowen, 854 F.2d 379 (10th Cir. 1988) (reasonableness test components for substantially justified)
United States v. 2,116 Boxes of Boned Beef, 726 F.2d 1481 (10th Cir. 1984) (articulation of reasonableness standard referenced by Gatson)