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(SS) Coronado v. Commissioner of Social Security
2:24-cv-00474
E.D. Cal.
Nov 15, 2024
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Background

  • 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)
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Case Details

Case Name: (SS) Coronado v. Commissioner of Social Security
Court Name: District Court, E.D. California
Date Published: Nov 15, 2024
Docket Number: 2:24-cv-00474
Court Abbreviation: E.D. Cal.