Yueh v. Kijakazi

Background

Julienne Yueh brought an action under 42 U.S.C. § 405(g) seeking review of the denial of her application for disability benefits. The parties stipulated to a remand, and the court remanded the case for further proceedings. On remand, the Commissioner granted Yueh’s application and awarded her ongoing benefits and $98,720.70 in past-due benefits.

Yueh’s attorney, Katherine Siegfried, sought $17,480 in fees under § 406(b) of the Social Security Act. A fee agreement provided for a fee of up to 25% of any past-due benefits resulting from a favorable disability decision. The Commissioner’s notice of award stated that 25% of Yueh’s past-due benefits was $24,680.18 and that amount was set aside for attorney fees. The court had also previously approved $1,541 in fees under the Equal Access to Justice Act, a statute allowing certain attorney-fee awards paid by the government.

Legal standard

Section 406(b) permits a federal court to award a reasonable fee to an attorney who represented a claimant in court, subject to a limit of 25% of the claimant’s past-due benefits. The court must independently review the requested fee for reasonableness, considering the quality of the representation, the result achieved, whether the fee would create a windfall, and whether the fee is disproportionate to the time spent. Fees awarded under § 406(b) must be coordinated with fees awarded under the Equal Access to Justice Act; the attorney must refund the smaller fee to the claimant.

Court’s analysis

The court found that Siegfried’s representation was not substandard and that Yueh achieved an excellent result by receiving $98,720.70 in past-due benefits. The 25% fee agreement was within the statutory limit. Siegfried reported spending 6.55 hours on the case and stated that her current non-contingency hourly rate for unrelated appellate work was $500. The requested fee would produce an effective hourly rate of $2,649.

The court concluded that the full requested amount was not reasonable. It emphasized that Yueh received benefits after a stipulated remand rather than after full briefing and that the requested fee would be a windfall given the number of hours billed. The court determined that a fee of $8,187.50—about 8.29% of the past-due benefits and an effective hourly rate of $1,250—better balanced the risks and results of the representation with the time spent and the need to protect Yueh from an unreasonably high deduction from her benefits.

Disposition

Judge Araceli Martinez-Olguin granted in part and denied in part Siegfried’s motion for attorney fees. The Commissioner was directed to certify $8,187.50 in fees under § 406(b), payable to Siegfried. Siegfried was ordered to refund the $1,541 Equal Access to Justice Act fee award to Yueh.