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In Re Oliver L. North (Fee Applications of Vincent Shields and Jerry Gruner)

Citations: 53 F.3d 1305; 311 U.S. App. D.C. 341; 1995 WL 263686Docket: Division 86-6

Court: Court of Appeals for the D.C. Circuit; May 9, 1995; Federal Appellate Court

Narrative Opinion Summary

In this case, two individuals sought reimbursement of attorneys' fees under section 593(f) of the Ethics in Government Act of 1978 after being investigated by Independent Counsel Lawrence E. Walsh. The court evaluated their petitions based on criteria outlined in the Act, confirming that both individuals were subjects of the investigation and not indicted, thereby qualifying them for reimbursement. The court reviewed the reasonableness of the fees, affirming the hourly rate charged by their attorney, William G. Hundley, as consistent with prevailing standards. Certain fees were disallowed, including those incurred for unrelated testimonies and activities, and a substantial reduction was applied to fees associated with the evaluation of the Independent Counsel's Final Report, deemed excessive. Ultimately, the court ordered the United States to reimburse $63,481.98 to one petitioner and $13,100 to the other, reflecting deductions for ineligible expenses. This decision underscores the court's adherence to statutory and precedential guidelines in determining fee reimbursement eligibility and reasonableness under the Ethics in Government Act.

Legal Issues Addressed

Definition and Criteria of 'Subject' in Independent Counsel Investigations

Application: The court interpreted 'subject' as a person whose conduct falls within the investigation's scope and who was aware that their conduct might attract scrutiny, confirming Shields and Gruner's status as subjects.

Reasoning: The term 'subject,' while not defined in the Act, has been interpreted by the court to mean a person whose conduct falls within the investigation's scope and who was aware that their conduct might attract scrutiny from independent counsel.

Disallowance of Fees Unrelated to Defense against Independent Counsel Investigations

Application: The court disallowed reimbursement for fees related to testimony in other prosecutions and activities not directly tied to defending against the independent counsel's investigation.

Reasoning: The court disallows several expense items that do not meet this criterion. Specifically, it denies reimbursement for $4,200 in fees for Shields and $825 for Gruner related to their testimony in other prosecutions.

Excessive Fees Related to Final Report Evaluation

Application: The court reduced fees related to the evaluation of the Independent Counsel's Final Report by half, considering them excessive compared to precedent.

Reasoning: In this instance, the fees related to the Final Report represent nearly twenty percent of Shields' total reimbursable fees. Consequently, following precedent, the court decides to halve the reimbursement for these fees, reducing it by $6,015.

Reasonableness of Attorneys' Fees

Application: The court assessed the reasonableness of attorneys' fees based on prevailing community standards and prior judicial interpretations, affirming an hourly rate of $300 as reasonable.

Reasoning: The court concludes that, given the reenactment of the statute, the existing judicial interpretations remain valid, thus affirming Hundley's hourly rate as reasonable for reimbursement calculations.

Reimbursement of Attorneys' Fees under Ethics in Government Act

Application: The court held that individuals who were subjects of an independent counsel investigation and not indicted are entitled to reimbursement of reasonable attorneys' fees incurred as a result of the investigation.

Reasoning: The court determined that both individuals were entitled to reimbursement as they were subjects of the investigation and had not been indicted.