Madeya v. Commissioner of Social Security

Background

The Social Security Administration initially denied Ryan C. Madeya’s application for benefits, and an Administrative Law Judge denied it after a hearing. Madeya filed this case under 42 U.S.C. § 405(g), which permits court review of a Social Security decision. After Madeya moved for judgment on the pleadings, the parties agreed to send the matter back to the agency. The court ordered an earlier attorney-fee payment of $7,828.52 under the Equal Access to Justice Act, a law that can provide fees for qualifying litigation against the government.

After the remand, the Commissioner found Madeya disabled and awarded $64,268 in past-due benefits. The Commissioner withheld $16,104.13—25 percent of the past-due benefits—for attorney fees. Madeya’s attorneys, Charles E. Binder and Patrick H. Busse, sought that amount under 42 U.S.C. § 406(b), which allows a court to approve a reasonable fee for an attorney’s representation in a Social Security case, subject to a 25-percent statutory limit. Their fee agreement also allowed a contingent fee of up to 25 percent of past-due benefits. The attorneys submitted records showing 37.3 hours of work in federal court and stated that they would return the earlier Equal Access to Justice Act payment to Madeya if the new fee request was granted.

Issues and analysis

The Government questioned the request’s timeliness and reasonableness. The court applied a 14-day filing deadline for fee applications. Under Second Circuit precedent, that period begins after the claimant receives notice of the benefits calculation. The court treated the September 19, 2021, “Notice of Change in Benefits” as the first notice of the relevant award amount. Because counsel filed the motion on October 5, 2021, the court found it timely.

The court then evaluated whether the requested fee was reasonable. It considered the quality and results of the representation, whether counsel delayed the case to increase the fee, and whether the fee was disproportionately large compared with the time spent. The court found that counsel submitted a detailed 36-page brief, obtained a remand that led to an award of benefits, did not unreasonably delay the proceedings, and handled the matter efficiently. The requested fee equaled an effective hourly rate of $431.75, which the court found did not require reduction.

Ruling

The court granted counsel’s motion for an award of $16,104.13. It also ordered counsel to return the $7,828.52 previously received under the Equal Access to Justice Act to Madeya. This order addressed attorney fees and did not decide the underlying eligibility question directly; the agency’s post-remand finding that Madeya was disabled had already resulted in the benefits award.