Merrell v. Block

ELR Citation: ELR 20868
No(s). 83-4258 (9th Cir. Aug 15, 1986)

The court rules that the Equal Access to Justice Act (EAJA) does not authorize an award of fees to a pro se litigant. The court holds that EAJA's definition of fees, 28 U.S.C. §2412, requires that an attorney have been retained. Section 2412(d)(2)(A) specifically defines fees and expenses to be "re...