Merrell v. Block
ELR Citation: ELR 20321 No(s). 83-4258 (9th Cir. Feb 5, 1987)
The court rules that the Equal Access to Justice Act (EAJA) does not authorize the award of attorney fees to a pro se litigant, but does authorize the award of litigation expenses. The court holds that EAJA's definition of fees, 28 U.S.C. §2412, requires that an attorney have been retained. Section...