(SS) Coronado v. Commissioner of Social Security
2:24-cv-00474
E.D. Cal.Nov 15, 2024Background
- Valentine Coronado, the plaintiff, filed a civil action in the Eastern District of California against the Commissioner of Social Security.
- The underlying dispute resulted in Coronado being deemed the prevailing party, making him eligible for attorney's fees under the Equal Access to Justice Act (EAJA).
- The parties reached a stipulation for an award of $7,500.00 in attorney's fees and $0 in costs to be paid by the government.
- The stipulated amount represents full compensation for legal services rendered in connection with this case.
- The stipulation addressed the assignment and potential offset of EAJA fees in accordance with Astrue v. Ratliff and related Treasury Offset Program rules.
- The court approved the stipulation and entered an order granting the agreed attorney's fees and costs to the plaintiff.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Award of EAJA attorney’s fees | Coronado is prevailing party, entitled to reasonable fees under EAJA | Position not substantially justified; no objection to stipulated amount | Attorney’s fees awarded to plaintiff, subject to Treasury Offset and stipulation terms |
| Assignment and payment of fees | Fees should be payable to attorney if assigned | Fees first payable to plaintiff, subject to offset and statutory restrictions | Fees payable to plaintiff, potentially to attorney if no offset and requirements waived |
| Admission of liability by government | None—stipulation as compromise | No admission of liability under EAJA or otherwise | Stipulation does not admit liability |
| Attorney's right to seek further fees | Retains right under 42 U.S.C. § 406(b) | No objection, subject to offset provisions | Attorney retains right to seek additional fees |
Key Cases Cited
- Astrue v. Ratliff, 560 U.S. 586 (2010) (EAJA fees belong to the plaintiff and are subject to offset by federal debts)
