Can a pro se attorney who represents one or more plaintiffs recover attorney's fees?

MultiRegion, United States of America

The following excerpt is from Zalaski v. City of Hartford, Docket No. 12-621-cv (2nd Cir. 2013):

Plaintiffs now argue that the district court's ruling rests on an error of law because the general rule that a pro se attorney cannot recover attorney's fees does not apply to a pro se attorney who represents one or more plaintiffs in addition to himself. See Schneider v. Colegio de Abogados de Puerto Rico, 187 F.3d 30, 32 (1st Cir. 1999) (awarding fees under 42 U.S.C. 1988 to prevailing attorney-plaintiff who represented another plaintiff in addition to himself).

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