U.S. Securities & Exchange Commission v. Chapman

MEMORANDUM ***

Daniel Chapman, an attorney appearing pro se, appeals the district court’s order denying his application for attorney’s fees under the Equal Access to Justice Act (“EAJA”). In the underlying action, Chapman (also appearing pro se) prevailed against the U.S. Securities and Exchange Commission (“SEC”) in a securities fraud case, charging that Chapman entered into a scheme to manipulate the market for the stock of Exotics.com.

1. The district court did not err in denying Chapman attorney’s fees. In Kay v. Ehrler, the Supreme Court determined that pro se attorney-plaintiff litigants…