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GAHAGAN v. U.S. CITIZENSHIP & IMMIGRATION SERVICES

Nos. 17-30898, 17-30901, 17-30999.

911 F.3d 298 (2018)

Michael W. GAHAGAN, Plaintiff-Appellant, v. UNITED STATES CITIZENSHIP & IMMIGRATION SERVICES, Defendant-Appellee. Michael Gahagan, Plaintiff-Appellant, v. United States Department of Justice; United States Department of Homeland Security; United States Immigration & Customs Enforcement; Executive Office of Immigration Review, United States Department of Justice, Defendants-Appellees. Michael W. Gahagan, Plaintiff-Appellant, v. United States Citizenship & Immigration Services; U.S. Customs & Border Protection, Defendants-Appellees.

United States Court of Appeals, Fifth Circuit.

FILED December 20, 2018.

Attorney(s) appearing for the Case

Michael Wayne Gahagan, Esq. , Immigration Law Firm of New Orleans, Metairie, LA, Mahesha P. Subbaraman , Attorney, Subbaraman, P.L.L.C., Minneapolis, MN, for Plaintiff-Appellant.

Jason M. Bigelow , Assistant U.S. Attorney, Kevin G. Boitmann , Assistant U.S. Attorney, Peter M. Mansfield , Assistant U.S. Attorney, U.S. Attorney's Office, Eastern District of Louisiana, New Orleans, LA, for Defendant-Appellee.

Before DAVIS, COSTA, and OLDHAM, Circuit Judges.

The question presented is whether attorneys appearing pro se can recover fees under the Freedom of Information Act ("FOIA"). The district court held no. We affirm.

I.

A.

Michael W. Gahagan is an immigration attorney. He uses FOIA to obtain government documents. In these consolidated...

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