Is a self-represented litigant entitled to attorney's fees?

Normally, we review an order granting or denying attorney's fees for abuse of discretion. (Crews v. Willows Unified School Dist. (2013) 217 Cal.App.4th 1368, 1379.) De novo review is appropriate here, however, where the question of whether a self-represented litigant is entitled to attorney's fees presents an issue of statutory interpretation. (See ibid.)

"California follows what is commonly referred to as the American rule, which provides that each party to a lawsuit must ordinarily pay his own attorney fees." (Trope v. Katz (1995) 11 Cal.4th 274, 278 (Trope).) However, attorney's fees are recoverable when authorized by contract or statute. (Id. at pp. 278-279.) The CPRA includes a mandatory fee-shifting statute, providing that "[t]he court shall award court costs and reasonable attorney's fees to the

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requester should the requester prevail in litigation filed pursuant to this section." ( 6259, subd. (d).)²