Spencer Woodman v. Department of Corrections

Summary

The Court held that the plaintiffs fully prevailed under FOIA because litigation was necessary to obtain the requested recordings, caused their disclosure, and resulted in plaintiffs receiving everything initially sought, despite permitted face blurring. It further held that pro bono representation may not be considered when determining reasonable attorney fees, while remanding for a properly supported fee calculation under the governing framework. The Court otherwise denied review of punitive damages.