Matos v. Saul
- Thomas Hixson
- 3:19-cv-02505
- U.S. District Court · Northern District of California
- 4
In Matos v. Saul, Judge Hixson granted counsel $21,474.90 in Social Security fees and required refund of $10,980.88 in earlier government-paid fees.
Hilda Matos and her attorney, Katherine R. Siegfried; the order authorizes payment of § 406(b) fees to Siegfried and requires her to refund the prior EAJA award to Matos.
What happened
In Matos v. Saul, Hilda Matos challenged the Social Security Commissioner’s denial of benefits. The court had previously sent the case back for further proceedings, and the Commissioner later awarded Matos $109,899.60 in past-due benefits.
Matos’s attorney, Katherine R. Siegfried, asked for fees under the Social Security Act based on a 25% contingency-fee agreement. The court found the requested fee reasonable because counsel obtained a favorable result, did not provide substandard representation, and sought less than the full amount allowed under the agreement.
Judge Hixson granted the motion and directed that $21,474.90 be certified as payable to Siegfried. He also ordered Siegfried to refund Matos the previously awarded $10,980.88 in fees under the Equal Access to Justice Act.
The detailed version
- Matos v. Saul · No. 3:19-cv-02505
- Thomas Hixson
- Apr. 14, 2021
Background
Hilda Matos brought an action under 42 U.S.C. § 405(g) seeking review of the Social Security Commissioner’s decision denying her benefits. On March 23, 2020, the court granted Matos’s summary judgment motion and remanded the case for further proceedings. The Commissioner later issued a favorable decision awarding Matos $109,899.60 in retroactive benefits.
Matos’s attorney, Katherine R. Siegfried, previously received an Equal Access to Justice Act (EAJA) fee award of $10,980.88. Siegfried then sought attorney’s fees under § 406(b) of the Social Security Act. Matos’s contingent-fee agreement allowed counsel to receive up to 25% of past-due benefits. The Social Security Administration had paid $6,000 to Matos’s administrative attorney and withheld the rest of the 25% for attorney’s fees.
Legal standard
Section 406(b) permits a court to award a claimant’s attorney a reasonable fee for work performed in court, subject to a cap of 25% of the claimant’s past-due benefits. The court must independently review the fee agreement for reasonableness. A fee may be reduced if counsel provided substandard representation, delayed the case to increase the benefits, or requested a fee that was too large compared with the time spent and the benefits obtained.
When an attorney receives fees under both § 406(b) and the EAJA, the attorney must refund the smaller fee to the claimant. The EAJA award is therefore offset against the § 406(b) award through that refund.
Court’s analysis
The court found that Siegfried’s requested fee was reasonable. The 25% contingency-fee agreement complied with the statutory cap. The court found no evidence of substandard performance and noted that counsel’s representation resulted in a substantial award of past-due benefits. Siegfried sought less than the full amount contemplated by the agreement to account for the $6,000 paid to Matos’s administrative attorney.
The court considered Siegfried’s 53.5 hours of work, the results achieved, and the risk of contingency representation. It found that the requested fee produced an effective hourly rate of approximately $401 and was not excessive in relation to the benefits obtained.
Disposition
The court granted counsel’s motion for attorney’s fees. It directed the Commissioner to certify $21,474.90 under 42 U.S.C. § 406(b), payable to Katherine Siegfried, and ordered counsel to refund the $10,980.88 EAJA fee award to Matos.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.