Martinez v. Secretary of Health and Human Services

Mr. Martinez (plaintiff) had his Social Security disability benefits terminated following a continuing disability investigation, a termination upheld by an administrative law judge and the appeals council; Martinez sought federal review, arguing the termination required evidence his medical condition had improved, while the Secretary of Health and Human Services (defendant) argued the medical-improvement standard did not apply. After an unrelated appellate decision held that disability benefits cannot be discontinued without a finding of medical improvement, the district court sua sponte reversed Martinez's termination and ordered his benefits reinstated. As the prevailing party, Martinez then sought attorney's fees under the Equal Access to Justice Act, but the Secretary argued its position was substantially justified because the court of appeals had not yet adopted the medical-improvement standard when the termination decision and litigation began; the district court denied Martinez's fee request, and he appealed.