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Keywords

attorneyappealpleasovereign immunity
attorneyappealclass actionsovereign immunity

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Adamson v. Bowen, 855 F.2d 668, 57 USLW 2144, 11 Fed.R.Serv.3d 606, 22 Soc.Sec.Rep.Serv. 698, Unempl.Ins.Rep. (CCH) P 14107A

Facts

Gerald K. Adamson brought individual and class claims against the Secretary of the United States Department of Health and Human Services after his claim for Social Security disability benefits was denied at all levels of administrative review, despite supporting reports from his treating physician. Adamson appealed to the federal district court for the District of Colorado, which reversed the Secretary's decision, found Adamson totally disabled, and imposed sanctions under Rule 11 for the Secretary's unsupported defense. Adamson also sought class certification, alleging an illegal policy of nonacquiescence by the Secretary regarding the weight given to treating physicians' reports.

In this action, Gerald K. Adamson brought individual and class claims against the Secretary of the United States Department of Health and Human Services. The individual claim was an appeal of the Secretary's denial of Social Security disability benefits.

Issue

1) Did the Equal Access to Justice Act waive sovereign immunity for Rule 11 sanctions against the United States? 2) Did the district court abuse its discretion in imposing Rule 11 sanctions? 3) Was the appeal from the denial of class certification moot, and did the district court apply the proper standard in making that determination?

The Secretary asserts that (1) the Rule 11 sanctions are barred by sovereign immunity; and (2) if not barred, the sanctions were imposed for conduct not deserving reprimand.

Rule

The Equal Access to Justice Act waives sovereign immunity for attorney's fee awards, and Rule 11 requires sanctions against attorneys for filings that are not well grounded in fact or law. The standard for evaluating whether a pleading violates Rule 11 is objective reasonableness.

The Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412 (1981), expressly waives immunity against attorney's fee awards.

Analysis

The court determined that the Equal Access to Justice Act indeed waived sovereign immunity for Rule 11 sanctions, allowing the district court to impose sanctions against the Secretary. The court found that the Secretary's defense was not supported by sufficient evidence, thus failing the objective reasonableness standard required by Rule 11. The court also concluded that the district court had applied an improper standard in denying class certification, as it incorrectly required common questions to predominate rather than merely exist.

We hold that the situation before us is such an unusual case, that the district court did not abuse its discretion by concluding that the agency's ruling was so lacking in evidentiary support that the Secretary should have conceded the merits of Adamson's complaint.

Conclusion

The court affirmed the imposition of Rule 11 sanctions against the Secretary but vacated the denial of class certification and remanded the case for reconsideration of that issue.

We AFFIRM the imposition of Rule 11 sanctions, VACATE denial of class certification, and REMAND to consider anew class certification.

Who won?

Gerald K. Adamson prevailed in the case as the court found in his favor regarding the imposition of sanctions against the Secretary and the recognition of his disability claim.

Adamson also sought certification of a class action, alleging that the Secretary had an illegal policy of nonacquiescence to the law of this circuit concerning the weight to be given to the reports of treating physicians.

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