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Michael W. Gahagan v. Citizenship & Immigration Services

Paid petition · United States Court of Appeals for the Fifth Circuit, No. 17-30898, 17-30901, 17-30999 · judgment December 20, 2018


Certiorari denied · October 21, 2019
Pre-decision estimate: 7% cert probability (95% interval 5%–10%)

Before the decision, about 1.7× the 4.1% base rate. The model weighted this up for a Fifth Circuit decision below, a circuit split argued in the petition, and a dissent in the court below (flagged in the petition), and down for a business respondent.

Questions presented

  1. Does the Fifth Circuit’s rule that all federal fee-award laws must be read identically (i.e., absent express textual differences) contravene this Court’s decision in Fogerty v. Fantasy Inc., 510 U.S. 517 (1994)—and Seventh Circuit precedent implementing Fogerty—which call for individual analysis of federal fee-award laws based on each law’s respective text, structure, history, and purpose?

  2. Does Congress’s use of the word “incurred” in a fee-award law refer solely to a legal obligation to pay attorney fees, as the Fifth Circuit has ruled, or does “incurred” also refer to any expended lawyer time, as the Seventh Circuit has ruled, thus allowing a feeaward law to compensate the work of pro bono attorneys, in-house attorneys, government attorneys, and self-representing attorneys alike?

  3. Does a fair reading of the federal Freedom of Information Act (FOIA) and its fee-award provision, 5 U.S.C. § 552(a)(4)(E), allow attorney-fee awards in “any case” under FOIA where the “complainant” has substantially prevailed—including cases where the complainant is a self-representing attorney?

Counsel of record

For petitioner
Mahesha Padmanabhan Subbaraman
Subbaraman PLLC

For respondent
Noel John Francisco
Jones Day

Case

Conference history
Distributed for 1 conference

Amicus briefs
1 cert-stage

Linked docket
18A1209

Proceedings

  1. Oct 21 2019
    Petition DENIED.
  2. Oct 02 2019
    DISTRIBUTED for Conference of 10/18/2019.
  3. Sep 26 2019
    Reply of petitioner Michael Gahagan filed.
  4. Sep 13 2019
    Brief of respondents United States Citizenship and Immigration Services, et al. in opposition filed.
  5. Aug 14 2019
    Brief amicus curiae of Public Record Media filed.
  6. Aug 07 2019
    Motion to extend the time to file a response is granted and the time is extended to and including September 13, 2019.
  7. Aug 06 2019
    Motion to extend the time to file a response from August 14, 2019 to September 13, 2019, submitted to The Clerk.
  8. Jul 11 2019
    Petition for a writ of certiorari filed. (Response due August 14, 2019)
  9. May 22 2019
    Application (18A1209) granted by Justice Alito extending the time to file until July 11, 2019.
  10. May 16 2019
    Application (18A1209) to extend the time to file a petition for a writ of certiorari from May 27, 2019 to July 11, 2019, submitted to Justice Alito.