Vermont Low Income Advocacy Council Inc. v. Usery

This appeal arises under the provision of the Freedom of Information Act (FOIA), § 552(a)(4)(E), authorizing a court to award reasonable attorney fees and other litigation costs in any case where the complainant has substantially prevailed. Although we do not agree with so much of the decision of the district court as indicates that an order directing production is a necessary condition for an award of attorney fees and costs under the FOIA, we affirm the denial of an award on the facts of this case.