A trial court properly refused to award the plaintiff in this Freedom of Information Act (FOIA) case attorney fees that were incurred after the defendant’s disclosure of the requested information but incurred as a result of seeking fees related to that disclosure – otherwise known as “fees for fees,” the Michigan Court of Appeals has ruled

Reasonable attorney fees shall be awarded where a party substantially prevails in obtaining everything that was initially sought in a FOIA action, and pro bono representation is not a factor.