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Culbertson v. Berryhill

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Supreme Court of the United States
Culbertson v. Berryhill
Term: 2018
Important Dates
Argument: November 7, 2018
Decided: January 8, 2019
Outcome
United States Court of Appeals for the 11th Circuit reversed and remanded
Vote
9-0
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh

Culbertson v. Berryhill is a case that was argued before the Supreme Court of the United States on November 7, 2018, during the court's 2018-2019 term. The court reversed and remanded the ruling of the United States Court of Appeals for the 11th Circuit, holding that "[t]he Social Security Act’s fee cap of 25 percent of past-due benefits imposed on attorneys who successfully represent Title II benefit claimants in court proceedings applies only to fees for court representation and not to aggregate fees for both court and agency representation," according to SCOTUSblog. The case came on a writ of certiorari to the Eleventh Circuit.[1][2][3]

HIGHLIGHTS
  • The case: Attorney Richard Culbertson represented four individuals in court who were appealing denials of social security disability benefits. Culbertson won all four cases, and then asked the district court to receive his attorney fees. Federal law states that an attorney who represents a client seeking social security benefits and wins can receive fees "not in excess of 25 percent of the total of the past-due benefits to which the claimant is entitled." The court decided his fees based on the precedent of the Eleventh Circuit Court, which applied the 25 percent cap to the aggregate amount received from representing the client in court and in front of the Social Security Administration. Culbertson appealed because other circuit courts had ruled that the cap applied only to fees received for court representation. The Eleventh Circuit Court affirmed the district court's ruling.
  • The issue: Whether fees subject to § 406(b)'s 25-percent cap include, as the Sixth, Ninth, and Tenth Circuits hold, only fees for representation in court or, as the Fourth, Fifth, and Eleventh Circuits hold, also fees for representation before the agency.[4]
  • The outcome: The court reversed and remanded, holding that "[t]he Social Security Act’s fee cap of 25 percent of past-due benefits imposed on attorneys who successfully represent Title II benefit claimants in court proceedings applies only to fees for court representation and not to aggregate fees for both court and agency representation," according to SCOTUSblog.[2]


    • You can review the lower court's opinion here.[5]

    Timeline

    The following timeline details key events in this case:

    • January 8, 2019: U.S. Supreme Court reversed and remanded the case
    • November 7, 2018: Oral argument
    • May 21, 2018: U.S. Supreme Court agreed to hear case
    • November 21, 2017: Petition filed with U.S. Supreme Court
    • June 26, 2017: Eleventh Circuit Court affirmed the district court decision to apply the 25 percent cap to the aggregate fees awarded

    Background

    Attorney Richard Culbertson represented four individuals in court who were appealing denials of social security disability benefits. Culbertson won all four cases, and then asked the district court to receive his attorney fees. Federal law states that an attorney who represents a client seeking social security benefits and wins can receive fees "not in excess of 25 percent of the total of the past-due benefits to which the claimant is entitled."

    The court decided his fees based on the precedent of the Eleventh Circuit Court, which applied the 25 percent cap to the aggregate amount received from representing the client in court and in front of the Social Security Administration. Culbertson appealed because other circuit courts (the Sixth, Ninth, and Tenth) had ruled that the cap applied only to fees received for court representation. The Eleventh Circuit Court affirmed the district court's ruling. The Fourth and Fifth Circuit Courts have also issued rulings in accordance with the Eleventh Circuit Court's decision. Culbertson appealed to the U.S. Supreme Court, which agreed to hear the case on May 21, 2018.[6]

    Question presented

    The petitioner presented the following question to the court:[4]

    Question presented:
    • Whether fees subject to § 406(b)'s 25-percent cap include, as the Sixth, Ninth, and Tenth Circuits hold, only fees for representation in court or, as the Fourth, Fifth, and Eleventh Circuits hold, also fees for representation before the agency.

    Audio

    • Audio of oral argument:[7]

    Transcript

    • Read the oral argument transcript here.

    Outcome

    Decision

    Justice Clarence Thomas delivered the unanimous opinion of the court. The court reversed and remanded the ruling of the Eleventh Circuit, holding that "[t]he Social Security Act’s fee cap of 25 percent of past-due benefits imposed on attorneys who successfully represent Title II benefit claimants in court proceedings applies only to fees for court representation and not to aggregate fees for both court and agency representation," according to SCOTUSblog.[2][3]

    Opinion

    In his opinion for the court, Justice Thomas wrote,

    “ Because the 25% cap in §406(b)(1)(A) applies only to fees for court representation, and not to the aggregate fees awarded under §§406(a) and (b), the judgment of the United States Court of Appeals for the 11th Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.[8] ”

    See also

    External links

    Footnotes

    1. ↑ Supreme Court of the United States, "17-773 Culbertson v. Berryhill," accessed October 26, 2018
    2. ↑ 2.0 2.1 2.2 SCOTUSblog, "Culbertson v. Berryhill," accessed January 9, 2018
    3. ↑ 3.0 3.1 3.2 United States Supreme Court, "Culbertson v. Berryhill," Opinion, January 8, 2019
    4. ↑ 4.0 4.1 Supreme Court of the United States, "17-1042 Culbertson v. Berryhill QPReport," accessed October 26, 2018
    5. ↑ SCOTUSblog, "Culbertson v. Berryhill," accessed October 26, 2018
    6. ↑ Oyez, "Culbertson v. Berryhill," accessed October 26, 2018
    7. ↑ Supreme Court of the United States, Culbertson v. Berryhill, argued November 7, 2018
    8. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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