Raines v. Shalala case brief

Raines v. Shalala case brief summary
44 F.3d 1355 (1995)

CASE SYNOPSIS

Appellant secretary of health and human services challenged the judgment of the United States District Court for the Northern District of Illinois, which awarded attorneys' fees and expenses to appellee claimant under the Equal Access to Justice Act, 28 U.S.C.S. § 2412(d)(2)(A), after appellee won entitlement to social security disability benefits and supplemental security income.

CASE FACTS

• William Raines (P) won entitlement to social security disability benefits and supplemental security income. 
• Raines sought attorney’s fees under the Equal Access to Justice Act (EAJA). 
• He requested that the attorney’s fees be awarded at a rate of $175 per hour. 
• He based this request on the claim that this was the prevailing market rate for this type of litigation given the limited availability of social security lawyers. 
• The court granted Raines’ request for attorney’s fees. 
• The Secretary of Health and Human Services (Secretary) appealed.

DISCUSSION

• Appellant secretary of health and human services contended the district court's decision to allow enhancement of an award of attorney's fees. 
• The court held that the specialized skills described by the district court in the area of social security law did not constitute the sort of expertise that was unattainable by a competent attorney who had diligently accomplished the necessary legal work. 
• The court also believed that the district court erroneously determined that appellee claimant's case was so complex that it required extraordinary lawyering skills. 
• Accordingly, the court held that the district court should not have permitted the enhancement of the fee award. 
• Appellant also contended that the district court erred by including the fees for administrative proceedings that were conducted after an earlier remand from the district court to the agency. 
• Here, the district court's order was entered pursuant to sentence four rather than sentence six. A sentence four remand terminated the district court's case. 
• Therefore, the administrative proceedings were not considered a part and parcel of the civil action.

OUTCOME

The court reversed the district court's decision to award an enhancement of attorneys' fees and expenses to appellee claimant under the Equal Access to Justice Act (EAJA). The district court abused its discretion in basing the enhancement of EAJA attorney fees on the "special factor" exception. The district court also erred in awarding attorney fees for the administrative proceedings because they followed a sentence four remand.

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