Fourth Circuit issues social security fee opinion

In Mudd v. Barnhardt, the Fourth Circuit held that although under the statute a court may only award attorney fees for court-related work in a Social Security case (no fees may be awarded for ALJ-level work), a district court may consider as one factor in its reasonableness determination, the time spent and work performed by counsel on the case when it was pending at the agency
level. According to the court:

This was appropriate insofar as it gave the district court a better understanding of factors relevant to its reasonableness inquiry, such as the overall complexity of the case, the lawyering skills necessary to handle it effectively, the risks involved, and the significance of the result achieved in district court.