Madron v. Astrue
2011 U.S. App. LEXIS 2351
| 10th Cir. | 2011Background
- Suzan Madron alleged disability due to back pain and respiratory problems and applied for benefits.
- Initial denial followed by administrative and district court reviews, with unfavorable outcomes on her claims.
- This court previously held the ALJ's credibility assessment and reading-level findings defective and remanded for an immediate award of benefits.
- Following remand, Madron obtained benefits and then sought EAJA fees and expenses against the United States.
- The district court denied EAJA fees, finding the government’s position substantially justified; Madron appeals this ruling.
- This court reviews the district court’s EAJA substantial-justification determination for abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in finding substantial justification | Madron contends government position was not substantially justified. | Astrue argues position was substantially justified despite merits on appeal. | No abuse; position reasonable under EAJA substantial-justification standard. |
| Whether Law of the Case precludes reconsideration of substantial-justification | Madron says Law of the Case prevents defending the earlier position. | District court properly considered reasonableness irrespective of merits. | Law of the Case argument rejected; two questions relevant, not barred. |
Key Cases Cited
- Hackett v. Barnhart, 475 F.3d 1166 (10th Cir. 2007) (abuse-of-discretion standard for EAJA appeals)
- Valley Forge Ins. Co. v. Health Care Mgmt., 616 F.3d 1086 (10th Cir. 2010) (appellate review limited to rational choices)
- Gatson v. Bowen, 854 F.2d 379 (10th Cir. 1988) (substantial justification test for EAJA: reasonableness even if wrong)
- Pierce v. Underwood, 487 U.S. 552 (Supreme Court, 1988) (substantial justification standard is one of reasonableness)