Melkonyan v. Sullivan
Headline: Court rules that 'final judgment' under the Equal Access to Justice Act means a court judgment ending the civil action, narrowing when disability claimants can file for attorney fees after agency remands.
Holding: A 'final judgment' under EAJA must be a court judgment that ends the civil action; the 30‑day fee deadline runs after the time to appeal that judgment has expired.
- Requires fee deadline to run from court's final judgment, not agency decision.
- May force claimants to seek fees only after the court reenters judgment following remand.
- Creates need for courts to clarify remand type to determine fee eligibility.
Summary
Background
A man who applied for Supplemental Security Income disability benefits had his first claim denied by an Administrative Law Judge and the agency's Appeals Council. He filed a federal lawsuit to review that denial. While the case was pending he filed a second benefits claim, which was approved with an effective date matching the first application. The district court entered a short order remanding the case to the Secretary "for all further proceedings" after the parties jointly asked for remand. On remand, the agency reversed and granted him benefits dating back to his original application. More than a year later he asked the district court for attorney fees under the Equal Access to Justice Act (EAJA).
Reasoning
The Court addressed whether the EAJA requires the 30‑day fee application deadline to run from an administrative agency decision or only from a final court judgment that ends the civil action. The Justices held that "final judgment" in EAJA means a judgment entered by a court that terminates the civil action, and the thirty‑day period runs after the time to appeal that court judgment has passed. The Court rejected the government's argument that the 1985 EAJA definition of "final judgment" expanded the term to include agency decisions. The opinion also explained a narrow exception when the district court keeps the action open and contemplates returning after remand; in that situation administrative work can count toward fees.
Real world impact
The Court vacated the appeals court judgment and sent the case back so the district court can clarify what kind of remand it ordered. If the court meant a remand under the statutory "sentence six," the Secretary must return to court so the court can enter a final judgment and the claimant can timely seek EAJA fees; if not, fees may not be available.
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