## Facts

- Shane A. Costa sought Social Security disability benefits based on mental-health conditions and physical pain.
- The agency denied benefits initially and on reconsideration; an ALJ found Costa not disabled.
- Costa obtained judicial review in the District of Oregon, where a magistrate judge (by consent) reversed and remanded because the ALJ improperly disregarded an examining psychologist’s opinions.
- Costa then moved for attorney’s fees under the Equal Access to Justice Act (EAJA), requesting compensation for 60.5 hours.
- The magistrate judge deemed the hours excessive for a “routine” Social Security case, citing the length of the opening brief and the lack of novel issues, and reduced compensable time to 41.1 hours.
- Costa appealed only the fee reduction.

## Issues

1. Whether the district court abused its discretion under the EAJA by reducing requested attorney hours based on a generalized “routine case” benchmark or de facto cap, rather than a case-specific assessment of reasonableness.

## Decision

- The Ninth Circuit vacated the EAJA fee award and remanded.
- The court held the magistrate judge abused discretion by effectively applying an informal cap or rule of thumb for “routine” Social Security cases.
- The district court was directed to reconsider the request using an individualized, record-based evaluation of the hours claimed.

## Legal Principles

- EAJA fee determinations require a reasonableness analysis of the hours worked; courts may reduce time that is excessive, redundant, or unnecessary only with specific, articulated reasons tied to the record.
- District courts may not apply de facto caps on compensable hours in Social Security disability cases, including default ranges (e.g., 20–40 hours) for “routine” matters.
- Social Security appeals are often highly fact-intensive and can require substantial time to review and synthesize extensive administrative records and complex medical evidence.
- The lodestar method (reasonable hours multiplied by a reasonable rate) governs EAJA fee calculations, subject to case-specific adjustments supported by detailed findings.

## Conclusion

The Ninth Circuit required individualized evaluation of EAJA fee requests in Social Security cases and rejected fee reductions grounded in generalized hour ceilings or “routine case” assumptions, vacating the reduced award and remanding for a record-based reassessment.


Costa v. Comm’r of Soc. Sec. Admin., 690 F.3d 1132 (9th Cir. 2012)