Is a plaintiff entitled to attorney's fees even if they represented themselves?

8 In Ellis v. Cassidy, supra, 625 F.2d 227, the defendant lawyers represented themselves. The appellate court held they were entitled to recover fees, because they had "actually suffered pecuniary loss, since they [were] required to take time away from their practices to prepare and defend the suit. [Citations.] ... The difficulty of placing a dollar value on the legal services performed, present in the situation where a lay defendant represents himself, is largely absent in the case of an attorney who has an established fees and billing practices. Further, these [pro se lawyers] did not seek out a chance for pro se litigation to compensate for an inactive practice; they were forced to defend against frivolous claims made by a plaintiff who is apparently bent on endless litigation." (Id. at p. 231.) The thrust of the decision is to award attorney's fees to rectify an injustice and to advance the policy of discouraging frivolous and harassing litigation by requiring the losing party to pay attorney's fees to his opponents even though they did not hire counsel to defend but instead represented themselves.