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Commissioner, Ins v. Jean, 496 U.S. 154 (1990)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Commissioner, Ins v. Jean, 496 U.S. 154 (1990)
Commissioner, Immigration and Naturalization Service v. Jean No. 89-601 Argued April 23, 1990 Decided June 4, 1990 496 U.S. 154
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE ELEVENTH CIRCUIT
Syllabus
The Equal Access to Justice Act (EAJA) directs a court to award fees and other expenses to private parties who prevail in litigation against the United States if, inter alia, the Government’s position was not "substantially justified." 28 U.S.C. § 2412(d)(1)(A). The District Court found that respondents were prevailing parties within the meaning of the EAJA, the Government’s position was not substantially justified, and there were no other special circumstances that would make a fee award unjust. The Court of Appeals upheld these findings, but remanded for recalculation of fees. Although the Government concedes that fees for time and expenses incurred in applying for fees are appropriate, it contends that respondents are ineligible for fees for services rendered during the substantial litigation over the fees unless the Court finds that the Government’s position in the fee litigation itself was not substantially justified.
Held: A second "substantial justification" finding is not required before EAJA fees are awarded for fee litigation itself. Pp. 158-166.
(a) The EAJA’s "substantial justification" requirement is a single finding that operates as a clear threshold for determining a prevailing party’s fee eligibility. Once a litigant has met all of the eligibility conditions for fees, the district court has the discretion to adjust the amount of fees for various portions of the litigation, guided by reason and the statutory criteria. See Hensley v. Eckerhart, 461 U.S. 424. There is no textual support for the position that the Government may assert a "substantial justification" defense at multiple stages of an action, since the EAJA refers only to a single "position," §§ 2412(d)(1)(A) and (d)(2)(D), that the Government has taken in the past, § 2412(d)(1)(B), in "any civil action," § 2412(d)(1)(A). Pp. 158-162.
(b) The Government’s argument that automatic awards of "fees for fees" will encourage exorbitant fee requests, generate needless litigation, and unreasonably burden the federal fisc is rejected. First, no fee award is automatic, since a district court always has discretion to fix the amount of the award once eligibility is established. In contrast, requiring courts to make a separate "substantial justification" finding regarding the Government’s opposition to fee requests would multiply litigation. Second, the EAJA’s purpose to eliminate the average person’s financial disincentive to challenge unreasonable governmental actions would be defeated if the Government could impose on prevailing parties the costs of litigating fee requests, costs that may exceed those incurred in litigating the claim’s merits. Pp. 162-166.
863 F.2d 759 (CA 11 1988), affirmed.
STEVENS, J., delivered the opinion for a unanimous Court.
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Chicago: U.S. Supreme Court, "Syllabus," Commissioner, Ins v. Jean, 496 U.S. 154 (1990) in 496 U.S. 154 496 U.S. 155. Original Sources, accessed November 25, 2024, http://originalsources.com/Document.aspx?DocID=N63SE54MQYMW9E6.
MLA: U.S. Supreme Court. "Syllabus." Commissioner, Ins v. Jean, 496 U.S. 154 (1990), in 496 U.S. 154, page 496 U.S. 155. Original Sources. 25 Nov. 2024. http://originalsources.com/Document.aspx?DocID=N63SE54MQYMW9E6.
Harvard: U.S. Supreme Court, 'Syllabus' in Commissioner, Ins v. Jean, 496 U.S. 154 (1990). cited in 1990, 496 U.S. 154, pp.496 U.S. 155. Original Sources, retrieved 25 November 2024, from http://originalsources.com/Document.aspx?DocID=N63SE54MQYMW9E6.
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