You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

In Re: Madison Guaranty Savings & Loan (Lewinsky Fee Application)

Citations: 352 F.3d 437; 359 U.S. App. D.C. 154; 2003 U.S. App. LEXIS 26404; 2003 WL 23021572Docket: Division 94-1

Court: Court of Appeals for the D.C. Circuit; December 30, 2003; Federal Appellate Court

Narrative Opinion Summary

This case involves a petition by an individual for the reimbursement of attorneys' fees under the Ethics in Government Act, arising from an investigation led by Independent Counsel Kenneth Starr. The petitioner, who had a significant relationship with a high-ranking official, became embroiled in a legal investigation following a civil lawsuit alleging misconduct by the official. The petitioner was subpoenaed, subsequently lied under oath, and was offered immunity, which she initially rejected. After negotiating transactional immunity, she sought reimbursement for legal fees, asserting they were incurred solely due to the investigation's unique nature under the Act. However, the court rejected this claim, applying the 'but for' test and determining that the investigation would likely have proceeded regardless of the Act, given the serious nature of the allegations. The court emphasized the distinction between transactional and use immunity, ultimately concluding that the petitioner's fees did not satisfy the statutory criteria for reimbursement. As a result, the petition for attorneys' fees was denied, setting a precedent for the application of the 'but for' test in similar cases involving high-profile investigations and legal proceedings.

Legal Issues Addressed

Immunity and Subject Status in Legal Proceedings

Application: Lewinsky's transactional immunity altered her subject status, affecting her eligibility for fee reimbursement.

Reasoning: The court disagrees with her assertion that she remained a subject for reimbursement until February 12, 1999, citing that after receiving immunity, it was unreasonable to expect that she could be accused.

Prosecution of Perjury and Obstruction of Justice

Application: The investigation into Lewinsky's alleged misconduct was justified independently of the Act, underscoring the gravity of perjury and obstruction charges.

Reasoning: The DOJ references past rulings, asserting that Lewinsky's alleged misconduct, including perjury and encouraging others to lie, warranted investigation regardless of the Independent Counsel statute.

Reimbursement of Attorneys' Fees under the Ethics in Government Act

Application: Lewinsky's petition for attorneys' fees was denied as she could not demonstrate that the fees were incurred solely due to the Act's requirements.

Reasoning: The court, presided over by Judges Sentelle, Fay, and Reavley, denied her petition, concluding that Lewinsky failed to demonstrate that her legal fees would not have been incurred but for the requirements of the Act.

The 'But For' Test for Fee Reimbursement

Application: The court determined Lewinsky's legal fees did not meet the 'but for' requirement, as the investigation could have proceeded without the statute.

Reasoning: The DOJ argues that Lewinsky misapplies the 'but for' test regarding the necessity of the Independent Counsel statute in her case.