Kraft v. Commissioner of Social Security
- Cisneros
- 3:23-cv-05434
- U.S. District Court · Northern District of California
- 4
In Shana Kraft v. Commissioner, Judge Cisneros granted counsel’s motion for $8,500 in Social Security Act attorney fees, payable from past-due benefits.
Shana Kraft and her attorney, Katherine Siegfried. The $8,500 fee is paid from Kraft’s past-due benefits, and Siegfried must reimburse Kraft $1,345 in previously awarded Equal Access to Justice Act fees.
What happened
In Shana Kraft v. Commissioner of Social Security, Shana Kraft challenged the denial of her disability benefits. The court remanded the case after the Commissioner agreed to send it back for further proceedings, and the Commissioner later awarded Kraft $109,599 in past-due benefits.
Kraft’s attorney, Katherine Siegfried, sought $8,500 under the Social Security Act. Kraft’s agreement allowed counsel to receive up to 25% of past-due benefits, and the Commissioner had set aside $27,399.75 for attorney fees. The court had also previously approved $1,345 in fees under the Equal Access to Justice Act.
Judge Cisneros granted the fee motion. The Commissioner must certify $8,500 for payment to Siegfried from Kraft’s past-due benefits, subject to the stated agency conditions, and Siegfried must reimburse Kraft the $1,345 in earlier government-paid fees.
The detailed version
- Kraft v. Commissioner of Social Security · No. 3:23-cv-05434
- Cisneros
- Dec. 9, 2025
Background
Shana Kraft sued under 42 U.S.C. § 405(g) to challenge the Commissioner of Social Security’s denial of her disability-benefits application. The court remanded the case for further proceedings after the Commissioner stipulated to a voluntary remand. The parties also stipulated to $1,345 in attorney fees under the Equal Access to Justice Act.
After the remand, the Commissioner approved Kraft’s application and awarded $109,599 in past-due benefits. Under Kraft’s contingency-fee agreement, she agreed to pay her attorney up to 25% of any past-due benefits resulting from a favorable disability decision. The Commissioner’s notice of award stated that 25% equaled $27,399.75 and that amount was set aside for attorney fees.
Fee Request and Analysis
Katherine Siegfried requested $8,500 under section 206(b) of the Social Security Act, 42 U.S.C. § 406(b). That provision permits a federal court to approve a reasonable fee for an attorney who represented a claimant in court, up to 25% of the claimant’s past-due benefits.
The court explained that it first considers the contingency-fee agreement and then independently checks whether the requested amount is reasonable. It found that Siegfried met that burden because the requested amount was below the fee permitted by Kraft’s agreement and the statutory cap, there was no evidence of inadequate performance, and the representation resulted in Kraft receiving $109,599 in past-due benefits.
Siegfried reported spending 5.7 hours on the case, producing an effective hourly rate of $1,491. The court nevertheless found the amount reasonable because contingency-fee work involves a substantial risk of losing, and the court considered the favorable result and the nature of the representation.
Ruling
The court granted counsel’s motion for attorney fees. It directed the Commissioner to certify $8,500 under section 406(b), payable to Katherine Siegfried. The award must be paid from Kraft’s past-due benefits in accordance with agency policy, to the extent those benefits remain available and were not used to pay a fee under section 406(a).
Because Kraft’s attorney had previously received $1,345 under the Equal Access to Justice Act, the court ordered Siegfried to reimburse Kraft that amount to offset the section 406(b) payment.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.