Omdahl v. West Iron County Board of Education

Summary

The court held that an attorney representing himself in a successful Open Meetings Act action may not recover actual attorney fees because an attorney-fee award requires separate attorney and client identities and an agency relationship. Because the plaintiff was proceeding pro se, no actual attorney fees existed for him to recover under the statute. Justice Weaver, dissenting, would have held that the statute permits recovery of actual, non-speculative fees by a pro se attorney.