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Gray Panthers Project Fund v. Thompson
304 F. Supp.2d 36 (D.D.C. 2004) ; Clearinghouse Number: 54065
Description
Finding Clear and Convincing Evidence of HHS Secretary’s Bad Faith, Court Awards Medicare Beneficiaries $173,922 in Attorney Fees
Abstract
The district court granted plaintiffs’ motion for attorney
fees after finding clear and convincing evidence that defendant
secretary of the U.S. Department of Health and Human Services had
acted in bad faith. The court said that, “while aware of the
unambiguous statutory mandates” of 42 U.S.C. §§
1395w-24(a)(1) and 1395w-21(d), defendant “nevertheless
engaged in conduct that required plaintiffs to undertake otherwise
unnecessary litigation to vindicate plain legal rights.”
Plaintiffs sued after defendant, in response to industry
complaints, extended the statutory deadline for Medicare+Choice
organizations to submit information about their coverage and
informed industry associations, but not beneficiaries, of the
extension. “In equally blatant contravention of statutory
authority,” in the court’s words, defendant announced
his intention to omit plan comparison data from a mailing to
beneficiaries. The court granted plaintiffs’ motion for
preliminary injunction. Plaintiffs sought fees under the Equal
Access to Justice Act: 28 U.S.C. § 2412(b), which authorizes
fees to the extent available under common law, including instances
of bad faith, with no statutory ceiling on the hourly rate; and 28
U.S.C. § 2412(d), which authorizes fees when the United
States’ position is not substantially justified. Defendant
did not dispute that his position was not substantially justified
under Section 2412 (d) but contended that he did not act in bad
faith and therefore attorney fees at the market rate as permitted
under Section 2412(b) were not warranted. The court said that
defendant’s “wanton conduct” offered little to
counter a finding of bad faith and that he had “no more right
to violate the law because he thinks he knows best than any other
public official.” The court concluded that defendant’s
actions, coupled with his failure to consult with or notify
beneficiaries, were “extraordinary circumstances”
warranting an award of bad-faith attorney fees.
