the decisions of the other circuits that have considered whether § 2412(d)(1)(A) authorizes fees for administrative proceedings that either preceded or followed district court litigation. See Maritime Mgmt., Inc. v. United States, 242 F.3d 1326, 1336 (11th Cir.2001) (denying pre-litigation fees incurred during administrative proceedings before the General Accounting Office); Friends of the Boundary Waters Wilderness v. Thomas, 53 F.3d 881, 887 (8th Cir.1995) (declining to award fees for pre-litigation expenses incurred during the Forest Service’s administrative appeals process because there was “no básis for extending Hudson [ ]” to cases “where the administrative proceedings precede the civil action”); Full Gospel Portland Church v. Thornburgh, 927 F.2d 628, 629, 631-33 (D.C.Cir.1991) (<HOLDING>), cert. denied 502 U.S. 1030, 112 S.Ct. 867,
holding that where us citizenship and immigration services was required to adjudicate naturalization applications it was required by the apa to do so within a reasonable time regardless of whether the immigration and naturalization act specifies a timeframe for action holding that because the district court does not retain jurisdiction sentencefour social security remands do not fall within the scope of hudson and noting that the court had limited hudson to a narrow class of qualifying administrative proceedings where the district court retains jurisdiction of the civil action pending the completion of the administrative proceedings internal quotation marks and citation omitted holding that the exclusionary rule generally does not apply to immigration proceedings holding that the plaintiffs could not recover fees for postlitigation administrative proceedings before the immigration and naturalization service because the pjroceedings under the immigration and nationality act lacked the specific features of the ssa proceedings that in hudson demonstrated the intimate tie between administrative and judicial proceedings holding that regulations that permitted an immigration official to reinstate removal orders violated the immigration and nationality act