Harrington v. Berryhill

District Courts did not err in granting plaintiffs’ requests for attorney fees under Equal Access to Justice Act, where plaintiffs were prevailing parties in appeals of denials of their applications for Social Security benefits. Moreover, Treasury Dept. did not err in intercepting SSA payment vouchers for said fees and applying said vouchers under Debt Collection Improvement Act to existing debts that plaintiffs had with Dept. of Education and Dept. of Health and Human Services. Although application of said vouchers to said debts left plaintiffs’ attorney with nothing in terms of fees, Dist. Ct. could properly deny plaintiffs’ requests to rescind instant administrative offsets, since said offsets were proper under Ratliff, 560 U.S. 586, because attorney fees are property of “prevailing party,” such that fee payments go directly to litigants and not their attorneys. Ct. of Appeals declined to exercise ancillary jurisdiction to entertain plaintiff’s collateral challenge to regulations that would allow instant offsets, since: (1) plaintiffs’ challenge pertains to actions taken by entity that was not party in instant action; (2) plaintiffs’ challenge is more appropriately addressed in new action under Administrative Procedure Act; and (3) instant challenge poses potential conflict of interest if allowed to proceed in instant case, since plaintiffs’ attorney is real party in interest to such challenge, and plaintiffs would potentially suffer by having their extinguished debts re-imposed should their attorneys prevail on challenge.