Nat'l Conference of Black Mayors v. Chico Cmty. Publ'g, Inc.

*575A requester of public records who successfully litigates against a public agency for disclosure of those records is entitled to reasonable attorney fees under the California *3Public Records Act1 (the Act). This case asks us to determine whether the Act also allows for an award of attorney fees to a requester when the requester litigates against an officer of a public agency in a mandamus action the officer initiated to keep the public agency from disclosing records it agreed to disclose.2 We conclude the answer is no. The Act limits the award of attorney fees to plaintiffs who prevail after…