MICHAEL MCNULTY, APPELLANT,
v.
LEWIS W. SULLIVAN, SECRETARY OF HEALTH AND HUMAN SERVICES, APPELLEE

8th Cir. | 1989-10-12
No. 89-1879
Before ARNOLD, FAGG, and BEAM, Circuit Judges.
886 F.2d 1074 United States Court of Appeals for the Eighth Circuit (1989) Caution
Cited by 4 cases

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.


Holding

The court held that the district court did not abuse its discretion by refusing an upward cost of living adjustment to attorney fees under the EAJA when the appellant failed to submit supporting proof.


Facts & Procedural History

Michael McNulty appealed the district court's order denying an upward cost of living adjustment to attorney fees under the Equal Access to Justice Act…

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.


Opinion of the Court
PER CURIAM.

PER CURIAM.

Michael McNulty appeals from the district court’s order refusing to grant an upward cost of living adjustment in the statutory hourly rate for attorney fee awards under the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412(d)(2)(A)(ii). We affirm.

The abuse of discretion standard governs our review. See Pierce v. Underwood, — U.S.-, 108 S.Ct. 2541, 2553, 101 L.Ed.2d 490 (1988); Brouwers v. Bowen, 823 F. 2d 273, 275 (8th Cir.1987). Although “the district court may, upon proper proof, increase the $75 per hour rate for attorney’s fees to reflect the increase in the cost of living,” Kelly v. Bowen, 862 F. 2d 1333, 1336 (8th Cir.1988), this increase is not automatic, Headlee v. Bowen, 869 F. 2d 548, 551-52 (10th Cir.1989); Oliveira v. United States, 827 F. 2d 735, 742 (Fed.Cir.1987). In this instance, McNulty failed to submit proof supporting his request for a higher fee to the district court.

Based on our review of the record, we cannot say the district court abused its discretion by refusing to make an upward adjustment in the fee awarded to McNulty’s attorney. Accordingly, we affirm.


Cases With Similar Vibessemantic neighbors from the corpus


Citator

Cited By

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw