Daniel C. v. Saul

Background

Daniel C., through his attorneys, sued the Commissioner of Social Security over the denial of his application for disability insurance benefits under Title II of the Social Security Act. In the earlier ruling, the court granted Daniel C.’s motion for summary judgment, denied the Commissioner’s motion for summary judgment, vacated the Commissioner’s decision as to steps four through five, and remanded the case for further proceedings.

Daniel C. then filed a petition for attorney fees under the Equal Access to Justice Act (EAJA). He requested $9,381.77 for 46.3 hours of legal work and $400 in costs for filing the complaint. His attorneys submitted an itemized list of their services and time.

Legal standard

The EAJA generally requires an award of attorney fees and expenses to a party who prevails in a civil action against the United States, including a case reviewing government administrative action, unless the government’s position was substantially justified or special circumstances would make an award unfair. The Commissioner bears the burden of showing substantial justification.

Court’s analysis and ruling

The Commissioner did not dispute that Daniel C. was the prevailing party and did not argue that the government’s position was substantially justified. The Commissioner also filed no response to the fee petition. The court interpreted that failure to respond as acquiescence to the requested fees and costs. The court found nothing in the record suggesting that an award would be unfair.

The court therefore granted the petition in full. It awarded Daniel C. $9,381.77 in attorney fees and $400 in costs. The court stated that this award fully and completely satisfied any claims for fees, costs, or expenses payable to Daniel C. in the matter under the EAJA.