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plaintiffjurisdictionattorneypleamotionclass action
plaintiffjurisdictionattorneytrialcorporation

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Singleton v. Apfel

Facts

In April 1994, Diane Singleton and two other named plaintiffs filed suit challenging a policy of the Commissioner of Social Security on behalf of a proposed class of similarly situated individuals. The policy involved offsetting retroactive Social Security disability benefits against retroactive Supplemental Security Income (SSI) benefits to avoid awarding double benefits to those eligible for both awards. The Commissioner moved to dismiss the claim of each named plaintiff for lack of jurisdiction, but the district court denied it as to Singleton. After the Commissioner reversed the challenged policy, the district court remanded Singleton's individual claim for an administrative determination of her benefits and declared the class action moot. Singleton later filed a motion for attorney's fees under the Equal Access to Justice Act, which the district court dismissed for lack of subject matter jurisdiction.

In April 1994, Diane Singleton and two other named plaintiffs filed suit challenging a policy of the Commissioner of Social Security on behalf of a proposed class of similarly situated individuals.

Issue

Whether the district court erred in finding that Singleton's EAJA application was untimely and whether the application, if timely, otherwise failed to meet the jurisdictional requirements of 2412(d)(1)(B).

The issues raised in this case are: (1) Whether the district court erred in finding that Singleton's EAJA application was untimely; and (2) Whether the application, if timely, otherwise failed to meet the jurisdictional requirements of 2412(d)(1)(B).

Rule

A timely EAJA fee application may be supplemented to meet the pleading requirements of 2412(d)(1)(B), which includes showing that the applicant is a 'prevailing party' and that the government's position was not substantially justified.

timely EAJA fee applications may be supplemented to meet the requirements of 2412(d)(1)(B).

Analysis

The court found that the district court erred in concluding that Singleton's EAJA application was untimely. It reasoned that the collateral order doctrine applied, allowing Singleton to file her application after the final judgment was rendered. The court also noted that a timely application could be supplemented to meet the statutory requirements, and thus, Singleton's application was not precluded despite any initial deficiencies.

In finding that Singleton's EAJA claim was untimely, the district court relied on the collateral order doctrine first elucidated by the Supreme Court in Cohen v. Beneficial Industrial Loan Corporation, 337 U.S. 541, 69 S. Ct. 1221, 93 L. Ed. 1528 (1949).

Conclusion

The court vacated the district court's order, ruling that Singleton's application for attorney fees was timely and that she was entitled to supplement her application to satisfy the statutory pleading requirements.

We conclude that the same logic should be applied in the instant case. We have previously found that EAJA applications may, in some circumstances, be filed before a final judgment has been entered.

Who won?

Plaintiff prevailed in the case because the court found that her application for attorney fees was timely and that she could supplement it to meet the statutory requirements.

Plaintiff prevailed in the case because the court found that her application for attorney fees was timely and that she could supplement it to meet the statutory requirements.

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