Valinda S. Kornhauser v. Commissioner of Social Security
2012 U.S. App. LEXIS 13504
| 11th Cir. | 2012Background
- Kornhauser challenged SSA disability denial in district court.
- District Court referred merits to a magistrate for R&R on the record.
- Magistrate recommended vacatur and remand; noted local-rule noncompliance (margins/footnotes).
- Magistrate suggested sanctions by reducing attorney’s fees to address the noncompliance.
- District Court adopted the R&R, vacated the SSA decision, remanded, and awarded Kornhauser final judgment; later EAJA fees were petitioned.
- Magistrate later recommended a fee of $4,037, sanctioning counsel for Rule 1.05(a) violations; Kornhauser objected.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the inherent power sanctions were proper | Kornhauser contends no bad-faith notice; due process required; sanctions inappropriate | Commissioner argues inherent power allows sanctions for abuse of process | Inconsistent due process; inherent sanction power misapplied; vacated as to EAJA award |
| Whether due process was violated in imposing sanctions | Counsel was not given opportunity to respond or show cause | Sanctions justified for margin/footnote violations | District Court abused discretion by not providing notice and opportunity to respond |
| Whether the EAJA award should be reduced due to sanctions | Stated intent of $5,000 stipulation should govern | Sanctions justified substantial reduction | EAJA award vacated; instructed to pay $5,000 to Kornhauser’s attorney |
| Whether magistrate had authority to sanction without show-cause process | No show-cause procedure; due process not followed | Sanction appropriate under inherent power | Sanction process flawed; improper reliance on sua sponte recommendation—vacated |
| Whether the court should remand and how fees are handled moving forward | Remand consistent with merits; fees to attorney | Sanctions should stand; fees adjusted | Remand order to be vacated in light of due-process concerns; award set at $5,000 |
Key Cases Cited
- Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (inherent power sanctions require due-process safeguards)
- In re Mroz, 65 F.3d 1567 (11th Cir. 1995) (bad faith required for invoking inherent power; due-process safeguards)
- Martin v. Automobili Lamborghini Exclusive, Inc., 307 F.3d 1332 (11th Cir. 2002) (inherent power includes sanctions to protect court administration)
- Aldana v. Del Monte Fresh Produce N.A., Inc., 578 F.3d 1283 (11th Cir. 2009) (abuse of discretion standard; due-process requirements for sanctions)
- Pedraza v. United Guar. Corp., 313 F.3d 1323 (11th Cir. 2002) (standard for reviewing district court sanctions)
- Donaldson v. Clark, 819 F.2d 1551 (11th Cir. 1987) (due-process considerations for sanctions; opportunity to respond)