Decided: June 10, 2014
The Fourth Circuit affirmed the district court’s denial of a social security claimant’s motion for attorney’s fees under the Equal Access to Justice Act (“the Act”).
Social Security claimant, Meyer, appealed the district court’s denial of his motion for attorney’s fees under the Act. The Act provides that a party who prevails in litigation against the United States is entitled to an award of attorney’s fees unless “the position of the United States was substantially justified” or “special circumstances make an award unjust.” 28 U.S.C. § 2412(d)(1)(A). The district court determined that Meyer prevailed in his lawsuit against the Commissioner of Social Security, but that attorney’s fees were unwarranted because the Commissioner had pursued a substantially justified position when he weighed the evidence of Meyer’s claim. In determining whether the Government’s position in a case is substantially justified, the Court looked beyond the issue on which the petitioner prevailed to determine, from the totality of the circumstances, whether the Government acted reasonably in causing the litigation, or in taking a particular stance during the litigation. In applying this reasonableness standard, the Court emphasized that the standard required looking to whether a reasonable person could have believed that the litigation position was correct. In this case, the Court agreed with the district court and considered the weight of evidence in favor of the Commissioner’s position; therefore, the Court affirmed the district court’s decision.