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Keywords

plaintifflitigationstatutesummary judgmentregulationdivorceappellee
plaintifflitigationstatutesummary judgmentregulationdivorceappellee

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Marcus v. Shalala

Facts

Plaintiffs challenged regulations involving two disability benefits programs under the Social Security Act: one for children under the Supplemental Security Income program of Title XVI of the Act and the other for surviving spouses and divorced spouses of deceased wage earners under 42 U.S.C. 402 of Title II of the Act. To qualify for disability benefits under these programs, the Secretary's rules and regulations required claimants to show that they had an impairment that was the same as or equivalent to one of the approximately 120 impairments in the Secretary's Listing of Impairments. Claimants who did not meet all of the specified medical criteria for any of the qualifying impairments in the Listing were denied benefits. The district court granted summary judgment in favor of the plaintiffs, ruling that the statute did not authorize the Secretary to engage in what it described as 'cookbook adjudication.'

Plaintiffs challenged regulations involving two disability benefits programs under the Social Security Act: one for children under the Supplemental Security Income program of Title XVI of the Act and the other for surviving spouses and divorced spouses of deceased wage earners under 42 U.S.C. 402 of Title II of the Act. To qualify for disability benefits under these programs, the Secretary's rules and regulations required claimants to show that they had an impairment that was the same as or equivalent to one of the approximately 120 impairments in the Secretary's Listing of Impairments. Claimants who did not meet all of the specified medical criteria for any of the qualifying impairments in the Listing were denied benefits. The district court granted summary judgment in favor of the plaintiffs, ruling that the statute did not authorize the Secretary to engage in what it described as 'cookbook adjudication.'

Issue

The main legal issue was whether the Secretary's position in the litigation was substantially justified under the Equal Access to Justice Act.

The main legal issue was whether the Secretary's position in the litigation was substantially justified under the Equal Access to Justice Act.

Rule

Under the EAJA, a court shall award to a prevailing party other than the United States fees and other expenses incurred by that party in any civil action brought by or against the United States unless the court finds that the position of the United States was substantially justified or that special circumstances make an award unjust.

Under the EAJA, a court shall award to a prevailing party other than the United States fees and other expenses incurred by that party in any civil action brought by or against the United States unless the court finds that the position of the United States was substantially justified or that special circumstances make an award unjust.

Analysis

The court applied the rule by determining that the Secretary's position was not substantially justified, as the district court had correctly assessed the cumulative litigation history and the Secretary's prelitigation conduct. The court noted that the Secretary's argument that her position was justified based on previous court rulings was not sufficient to meet the standard of substantial justification.

The court applied the rule by determining that the Secretary's position was not substantially justified, as the district court had correctly assessed the cumulative litigation history and the Secretary's prelitigation conduct. The court noted that the Secretary's argument that her position was justified based on previous court rulings was not sufficient to meet the standard of substantial justification.

Conclusion

The court affirmed the award of costs and fees to plaintiff benefit recipients because appellee secretary was not substantially justified in her litigation position, and the cumulative litigation history justified the award. The court reversed the portion of the judgment adjusting the fees to current rates.

The court affirmed the award of costs and fees to plaintiff benefit recipients because appellee secretary was not substantially justified in her litigation position, and the cumulative litigation history justified the award. The court reversed the portion of the judgment adjusting the fees to current rates.

Who won?

Plaintiff benefit recipients prevailed in the case because the court found that the Secretary's position was not substantially justified, and the cumulative litigation history supported the award of fees.

Plaintiff benefit recipients prevailed in the case because the court found that the Secretary's position was not substantially justified, and the cumulative litigation history supported the award of fees.

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