Sprinkle v. Colvin
United States Court of Appeals for the Seventh Circuit
777 F.3d 421 (2015)
Facts
Stephen Sprinkle (plaintiff) successfully sought judicial review in a United States district court of the denial of his application for Social Security supplemental income by the Commissioner of the Social Security Administration, Carolyn Colvin (defendant). Sprinkle was awarded attorney’s fees in accordance with the Equal Access to Justice Act (EAJA), successfully arguing that the commissioner’s litigation position was not substantially justified. Sprinkle requested an award based on an hourly rate of $173.38, the statutory rate of $125 adjusted for inflation from the time most of the legal work was performed, based on the Consumer Price Index (CPI). Sprinkle submitted affidavits from four Social Security disability attorneys who had rates between $250 and $500, well over the statutory cap. However, the district court denied Sprinkle’s cost-of-living adjustment, finding that aside from conclusory statements, Sprinkle had failed to submit evidence sufficient to meet his burden of proving that there were increased costs for providing adequate legal services due to inflation, as required by circuit precedent. Sprinkle appealed.
Rule of Law
Issue
Holding and Reasoning (Williams, J.)
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