National Public Radio, Inc. v. U.S. Central Command

CourtDistrict Court, S.D. California
DecidedSeptember 8, 2025
Docket3:21-cv-01079
StatusUnknown

This text of National Public Radio, Inc. v. U.S. Central Command (National Public Radio, Inc. v. U.S. Central Command) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Public Radio, Inc. v. U.S. Central Command, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT 11 SOUTHERN DISTRICT OF CALIFORNIA 12 13 NATIONAL PUBLIC RADIO, INC, et Case No. 21-cv-1079-MMA-AHG al., 14 NOTICE AND ORDER PROVIDING Plaintiffs, 15 TENTATIVE RULINGS RE: v. PLAINTIFFS’ MOTION FOR 16 ATTORNEYS’ FEES AND COSTS 17 U.S. CENTRAL COMMAND, et al., Defendants. [Doc. No. 74] 18 19 20 21 22 23 On September 16, 2025, Plaintiffs National Public Radio, Inc. (“NPR”), and 24 Graham Smith (collectively “Plaintiffs”) and Defendants U.S. Central Command 25 (“CENTCOM”) and U.S. Department of Defense (“DoD”) (collectively “Defendants”) 26 will appear for a hearing on Plaintiffs’ motion for attorneys’ fees and costs. Doc. No. 74. 27 In anticipation of the hearing, the Court issues the following tentative ruling 28 GRANTING IN PART Plaintiffs’ motion. 1 I. LEGAL STANDARD 2 The Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”), provides that “[t]he 3 court may assess against the United States reasonable attorney fees and other litigation 4 costs reasonably incurred in any case under this section in which the complainant has 5 substantially prevailed.” 5 U.S.C. § 552 (a)(4)(E)(i). A plaintiff “substantially prevails” 6 if they obtain relief through “a judicial order, or an enforceable written agreement or 7 consent decree; or . . . a voluntary or unilateral change in position by the agency, if the 8 complainant’s claim is not insubstantial.” Id. at § 552 (a)(4)(E)(ii)(I)–(II). Upon 9 obtaining either, a plaintiff “is deemed ‘eligible’ for a fee award.” Poulsen v. Dep’t of 10 Def., 994 F.3d 1046, 1050 (9th Cir. 2021). 11 Eligibility alone, however, does not guarantee a plaintiff FOIA attorneys’ fees. Id. 12 Should they prove eligible, the court must next determine whether they are entitled to 13 those fees. Id. In doing so, it considers at least four factors: “(1) the public benefit from 14 disclosure[;] (2) any commercial benefit to the plaintiff resulting from disclosure[;] (3) 15 the nature of the plaintiff's interest in the disclosed records[;] and (4) whether the 16 government’s withholding of the records had a reasonable basis in law.” Schoenberg v. 17 F.B.I., 2 F.4th 1270, 1275 (9th Cir. 2021); see also Davy v. C.I.A., 550 F.3d 1155, 1159 18 (D.C. Cir. 2008) (“Davy II”). These factors are non-exhaustive, and none are dispositive. 19 Schoenberg, 2 F.4th at 1275–76; Long v. I.R.S., 932 F.2d 1309, 1313 (9th Cir. 1991). 20 The court may, in its discretion, consider any other factors it deems relevant. Id. 21 A “plaintiff who has proven both eligibility for and entitlement to fees must submit 22 his fee bill to the court” so that it may scrutinize “(a) the number of hours expended[;] 23 and (b) the hourly fee claimed” to determine whether those amounts are reasonable. 24 Long, 932 F.2d at 1313–14. “If these two figures are reasonable, then there is a strong 25 presumption that their product, the lodestar figure, represents a reasonable award.” Id. at 26 1314 (quoting Jordan v. Multnomah Cnty., 815 F.2d 1258, 1262 (9th Cir.1987)) (internal 27 quotation marks omitted). “The court may authorize an upward or downward adjustment 28 from the lodestar figure if certain factors relating to the nature and difficulty of the case 1 overcome this strong presumption and indicate that such an adjustment is necessary.” Id. 2 At this stage, however “the only room for discretion concerns the reasonableness of the 3 amount requested.” Id. The Court will address each step in turn. 4 II. DISCUSSION 5 As a preliminary matter, though the Court understands that the parties have 6 “resolved all outstanding issues related to document searches,” Doc. No. 70 at 2,1 the 7 case remains open. This motion is therefore procedurally distinct from one seeking 8 attorneys’ fees after entry of judgment or dismissal post-settlement. However, “[i]nterim 9 fees are available to FOIA litigants . . . ” even when a case remains ongoing. Rosenfeld 10 v. United States, 859 F.2d 717, 723–25 (9th Cir. 1988); accord Hall v. C.I.A., 115 F. 11 Supp. 3d 24, 27 (D.D.C. 2015). Thus, the Court tentatively finds the motion timely. 12 Turning to their motion, Plaintiffs argue that they are both eligible and entitled to 13 attorneys’ fees in this action and submit a request for “$438,209.50 in attorneys’ fees and 14 $6,566.75 in costs, for a total award of $444,776.25,” which they argue is reasonable. 15 See Doc. No. 74 at 20. Defendants assert that Plaintiffs should receive no attorneys’ fees, 16 arguing that: (1) it is “questionable” whether Plaintiffs are eligible for attorneys’ fees; (2) 17 that even if eligible, Plaintiffs are not entitled to attorneys’ fees; and (3) that the amount 18 they request is unreasonable, “excessive[,] and punitive.” Doc. No. 75 at 14–27. 19 A. Eligibility 20 As set forth at the outset, a plaintiff is eligible for attorneys’ fees if they 21 “substantially prevail[]” by obtaining relief through “a judicial order, or an enforceable 22 written agreement or consent decree; or . . . a voluntary or unilateral change in position 23 by the agency, if the complainant’s claim is not insubstantial.” 5 U.S.C. at § 552 24 (a)(4)(E)(ii)(I)–(II); Poulsen, 994 F.3d at 1050. A judicial order renders a plaintiff 25 eligible for attorneys’ fees if it materially alters the parties’ legal relationship and 26 provides at least some relief on the merits. See Davy v. C.I.A., 456 F.3d 162, 164–65 27

28 1 (D.C. Cir. 2006) (“Davy I”); Poulsen 994 F.3d at 1052 (approving Davy I’s approach). 2 At the “eligibility” stage, the Court need not “look behind the judicial order and ascertain 3 how it came into existence.” See Poulsen, 994 F.3d at 1051. “Rather, it requires only the 4 entering of an order of the sort described in that subsection.” Id. 5 First, the Court tentatively finds that its order denying Defendants’ motion to 6 dismiss does not render Plaintiffs eligible for attorneys’ fees because it made no 7 determinations that altered the parties’ legal relationship and provided no relief on the 8 merits. See generally Doc. No. 12. Instead, the parties maintained the same legal 9 relationship after the order as they did before: Plaintiffs continued to prosecute their case 10 against Defendants. See Oil, Chem. & Atomic Workers Int’l Union, AFL-CIO v. Dep’t of 11 Energy, 288 F.3d 452, 458 (D.C. Cir. 2002) (“OCAW”), superseded by statute on other 12 grounds (“Surviving a motion to dismiss does not alter the legal relationship between 13 parties.”). 14 As to the Ninth Circuit’s decision in this matter, however, the Court tentatively 15 finds that it renders Plaintiffs eligible for attorneys’ fees. The Ninth Circuit reversed the 16 Court’s determination that Defendants had conducted an adequate search at summary 17 judgment—a ruling that determined whether Defendants violated their statutory duties 18 and afforded Plaintiffs some relief on the merits of their claim, even if incomplete relief. 19 See The Sierra Club v. E.P.A., 75 F. Supp. 3d 1125, 1141 (N.D. Cal. 2014) (“Sierra 20 Club”) (“[E]ven if Plaintiffs did not achieve all relief sought . .

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National Public Radio, Inc. v. U.S. Central Command, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-public-radio-inc-v-us-central-command-casd-2025.