The Michigan Supreme Court reversed the Court of Appeals' award of attorneys fees to the in pro per attorney under the Open Meetings Act in Omdahl v. West Iron Board of Education. The Open Meetings Act allows the recovery of "actual attorney fees."

The Court reasoned that an "attorney" implies an agency an agency relationship with another person or entity. Therefore, to obtain attorney fees under the Act, the attorney has to represent another, and not himself. The majority opinion did not analyze whether the attorney fees were actually incurred.