The following excerpt is from Miller-Wohl Co., Inc. v. Commissioner of Labor and Industry State of Mont., 694 F.2d 203 (9th Cir. 1982):
Even if we could deem them parties, the American rule requires each party to bear its own attorney fees absent contrary contractual or statutory provisions. Exceptions are narrowly circumscribed. United States v. Standard Oil Co. of California, 603 F.2d 100, 103 (9th Cir.1979).
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