In the case of Donna E. Shalala, Secretary of Health and Human Services v. Richard H. Schaefer in 1992, the Supreme Court ruled on how to calculate attorney's fees for successful Social Security claimants under Section 206(b) of the Social Security Act (SSA). The issue arose when Mr. Schaefer successfully appealed a denial of his disability benefits but disagreed with how much his lawyer should be paid from his past-due benefits as stipulated by SSA rules. He argued that courts should consider all work done throughout litigation while calculating these fees, including time spent at administrative proceedings before filing a civil action in court. The Supreme Court held that only work performed after judgment in court could be considered for this calculation and not any prior administrative proceedings or efforts made before filing a lawsuit in federal court. This decision clarified an important aspect regarding attorney's fee calculations under SSA rules.

In the dissenting opinion for Shalala v. Schaefer, Justice Blackmun argued that the majority's decision to limit attorney fee awards under the Social Security Act was incorrect and unfair. He contended that Congress intended for attorneys representing social security claimants to be adequately compensated for their work in order to encourage competent representation of these often vulnerable individuals. The majority’s interpretation would discourage lawyers from taking on such cases due to inadequate compensation, thereby undermining access to justice for those seeking benefits. Furthermore, he disagreed with the majority's view that a "judgment" only occurs when there is a final decision after remand; instead, he believed an earlier court ruling could also constitute a judgment eligible for attorney fees calculation.