Unreported / Non-Citable
Background
Catrina Castaneda filed a Social Security case against the Commissioner of Social Security in the U.S. District Court for the Eastern District of California, Case No. 1:26-cv-4339-CDB. Both parties consented to the jurisdiction of a U.S. magistrate judge for all proceedings under 28 U.S.C. § 636(c)(1). On September 21, 2026, the court granted the parties' stipulated request for voluntary remand and remanded the case under sentence four of 42 U.S.C. § 405(g) to the Commissioner for further proceedings.
On October 6, 2026, Castaneda filed a stipulation requesting an award of attorney fees under the Equal Access to Justice Act, 28 U.S.C. § 2412(d), in the amount of $4,738.87 for her counsel, Andrea Banks. The parties agreed that the award should be made payable to Castaneda, but if the Department of the Treasury determined that she did not owe a federal debt, the Commissioner would cause the fees, expenses, and costs to be paid directly to her counsel.
The pending request came before the court as Document 16, and the court issued its order on October 15, 2026 as Document 17. The order is an EAJA fee award following a sentence-four remand, not a merits decision on Social Security benefits.
The Court’s Holding
The court granted Castaneda's stipulated EAJA fee request. It found that she was a prevailing party because a party who wins a sentence-four remand under 42 U.S.C. § 405(g) qualifies as prevailing, citing Shalala v. Schaefer, and it found her fee filing timely under Ninth Circuit precedent. Under the EAJA, a court must award fees to a prevailing party unless the government's position was substantially justified or special circumstances make an award unjust.
The court found that the government did not show its position was substantially justified, that there were no special circumstances making an award unjust, and that the Commissioner did not oppose the requested relief. It also found the requested amount reasonable: even at the published 2025 maximum hourly rate of $258.46, $4,738.87 would reflect roughly 18 hours of attorney time, while counsel's timesheet showed 19.3 hours spent on intake, reviewing and outlining the approximately 1,185-page administrative record, preparing briefing, and settlement-related work.
The operative order grants the stipulated request and directs the Commissioner to pay $4,738.87 to Castaneda as the prevailing party under the stipulation's terms. The fees remain subject to any Treasury Offset Program offset; if the Commissioner determines on effectuation that no offset applies, payment is to be made directly to counsel Andrea Banks.
Key Takeaways
- A Social Security claimant who obtains a sentence-four remand is a prevailing party eligible to seek attorney fees under the Equal Access to Justice Act.
- The court treated the government's failure to show substantial justification, the absence of special circumstances, and the Commissioner's non-opposition as separate grounds supporting the EAJA award.
- The $4,738.87 award was found reasonable against the statutory maximum rate and the roughly 1,185-page administrative record, with 19.3 hours documented by counsel's timesheet.
- EAJA fees are payable to the prevailing plaintiff but are routed directly to counsel only if the Treasury Offset Program does not require an offset for a federal debt.
- Because both parties consented under 28 U.S.C. § 636(c)(1), the magistrate judge issued the final fee order; the public docket entry identifies the signing judge as Magistrate Judge Christopher D. Baker.
Why It Matters
The order shows the standard post-remand EAJA pathway in Social Security litigation: a sentence-four remand establishes prevailing-party status, and the court then separately examines substantial justification, special circumstances, timeliness, and reasonableness before fixing the fee amount.
It also illustrates the practical operation of Astrue v. Ratliff in EAJA cases: the award is legally payable to the plaintiff, but the Treasury Offset Program determines whether funds are instead transmitted directly to counsel because the plaintiff owes no qualifying federal debt.