Chynoweth v. Sullivan case brief

Chynoweth v. Sullivan case brief summary
920 F.2d 648 (1990)

CASE SYNOPSIS

Appellant widow appealed the order of the United States District Court for the District of Ohio, which denied her request to exceed the $ 75 per hour cap on attorney's fees awarded to her pursuant to the Equal Access to Justice Act (EAJA).

CASE FACTS
A widow filed a claim with the Social Security Administration for Disabled Widow's Insurance benefits. Her application was denied following an administrative hearing, and the denial was affirmed on appeal. The legal client then sought judicial review.

DISCUSSION

• The district court adopted the recommendation of the magistrate that determination of benefits failed to consider the widow's impairments in combination. 
• On remand, the administrative law judge applied the standard enunciated by the district court and found the widow entitled to benefits. 
• She petitioned the district court for attorney's fees of $ 130 per hour pursuant to the EAJA. The district court disallowed her request to exceed the $ 75 per hour cap on attorney's fees, and the widow appealed. 
• The judgment was affirmed, and the court held that the counsel's expertise in Social Security benefits law did not constitute a "special factor" under the statute justifying an additional increase in the $ 75 rate.

OUTCOME

The judgment of the district court was affirmed.

Recommended Supplements for Administrative Law
Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)