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In Re Oliver L. North (Corr Fee Application)

Citations: 56 F.3d 261; 312 U.S. App. D.C. 297; 1995 WL 339936Docket: Division 86-6

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

Narrative Opinion Summary

This case involves a former U.S. Ambassador who sought reimbursement for attorneys' fees incurred during an investigation by Independent Counsel under the Ethics in Government Act of 1978. The petitioner, identified as a subject of the investigation, claimed fees for representation during an inquiry into the Iran/Contra affair. Despite being granted immunity and not indicted, the petitioner argued for fee reimbursement under 28 U.S.C. Sec. 593(f)(1), asserting continued subject status and reasonable apprehension of prosecution. The court evaluated the criteria for subject status, the impact of immunity, and the reasonableness of the fees requested. The Attorney General's input was limited due to insufficient information, but the court concluded that the petitioner met the requirements for reimbursement during a specific timeframe. The court awarded $18,155.37, covering attorneys' fees and expenses deemed reasonable, while addressing and rejecting challenges to the hourly rates. The decision underscored the complex interplay between immunity grants and subject status in fee reimbursement cases under the Act.

Legal Issues Addressed

Definition and Criteria for 'Subject' Status

Application: Corr was deemed a subject of the investigation based on the independent counsel's acknowledgment and his awareness of potential accusations, meeting the statutory definition for fee reimbursement purposes.

Reasoning: The term 'subject' is defined by the court as someone whose conduct falls within the independent counsel's investigation, and who was aware at the time of incurring fees that they could be accused.

Evaluation of Reasonable Fees

Application: The Court found Corr's claimed fees and hours reasonable, awarding compensation based on documented expenses and previously contested hourly rates.

Reasoning: The hours and expenses documented were found reasonable, leading to an award of $18,155.37 for attorneys' fees and expenses incurred during this period.

Impact of Immunity on 'Subject' Status

Application: After being granted immunity, Corr's status as a subject was questioned, reflecting on whether he maintained a reasonable apprehension of prosecution post-immunity.

Reasoning: However, after Corr received grants of immunity for grand jury testimony, it is uncertain whether he maintained his subject status, as immunity could negate ongoing subject status.

Reimbursement of Attorneys' Fees under the Ethics in Government Act of 1978

Application: The court determined that Edwin G. Corr was entitled to reimbursement for reasonable attorneys' fees incurred during the investigation as he met the criteria outlined in 28 U.S.C. Sec. 593(f)(1).

Reasoning: The Court determined that Corr is entitled to reimbursement for reasonable fees incurred during the investigation, as he was a subject of the inquiry and no indictment was brought against him.