ALARCON, Circuit Judge:
Appellant William E. Brock, III, Secretary of Labor for the United States Department of Labor (hereinafter the Secretary) appeals from the district court's judgment dismissing his complaint challenging a union election conducted by appellee Writers Guild of America, West, Inc. (hereinafter the Guild), and from the district court's sua sponte award of attorneys' fees to the Guild. This appeal requires us to resolve a novel question of...
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