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Schoolcraft v. Shalala
No. 91-1643 (8th Cir. Apr. 6, 1995) ; Clearinghouse Number: 45479
Description
Plaintiffs Awarded $36,000 in Challenge to Minnesota’s Standards for Determining Disability Based on Alcoholism or Substance Abuse
Abstract
The Eighth Circuit has granted plaintiff disability
claimants’ motion for attorney fees and costs in this class
action challenging the Minnesota Disability Determination
Service’s and HHS’s standards and practices for
determining disability based on alcoholism or substance abuse. The
district court had denied plaintiffs’ motion for class
certification and dismissed the action for lack of jurisdiction
under 42 U.S.C. § 405(g). On appeal, the Eighth Circuit
reversed. Defendants appealed to the Supreme Court. Pending that
appeal, the parties settled, contingent on vacatur of the Eighth
Circuit’s decision. The Supreme Court, however, denied the
parties’ joint motion for certiorari, vacatur of the Eighth
Circuit’s decision, and remand to the district court.
Subsequently, the parties stipulated a settlement that expressly
reserved the issue of attorney fees. Arguing that they were
prevailing parties under the Equal Access to Justice Act,
plaintiffs sought a total of $104,080 in fees. Plaintiffs argued
that they were entitled to fees for time spent following the
district court’s decision and that hourly rates ranging from
$185 to $210 per hour were appropriate. The court of appeals
awarded plaintiffs $36,000, based on an hourly rate of $120. The
court reduced the total number of hours claimed by plaintiffs by 50
percent because they did not completely prevail. Noting that there
was no substantial justification for the extent of the litigation,
the court held that, although HHS had a justifiable right to
challenge the jurisdictional issue before the district court, it
had never satisfactorily explained why the suit was not settled
sooner.
