Gahagan v. USCIS, 911 F.3d 298 (5th Cir. 2018) (Oldham, J.)

Gahagan v. USCIS, 911 F.3d 298 (5th Cir. 2018) (Oldham, J.)

Re:  Request for records concerning requester's client's removal proceedings

Disposition:  Affirming the district court's denial of requester's motion for attorney fees

• Attorney Fees:  The Court of Appeals for the Fifth Circuit "hold[s] pro se attorneys are ineligible for fee awards under FOIA."  The court relates that the requester "made each request in his own name."  The court "note[s] [that] FOIA's text supports the result precedent commands."  The court explains that "[b]ecause [the requester] had no legal obligation to pay himself, he did not 'incur' any attorney fees under the general rule."