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5 canonical passages across 4 cases, quoted by 51 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from Davy v. Central Intelligence Agency.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Davy v. Central Intelligence Agency Anchor | green | “(1) the public benefit derived from the case; (2) the commercial benefit to the plaintiff; (3) the nature of the plaintiffs interest in the records; and (4) the reasonableness of the agency's withholding of the requested documents.” | 14 |
| 2 | Davy v. Central Intelligence Agency | green | “no one factor is dispositive, although the court will not assess fees when the agency has demonstrated that it had a lawful right to withhold disclosure.” | 13 |
| 3 | Nationwide Building Maintenance, Inc. v. Arthur Sampson, Administrator, U. S. General Services Administration | green | “contemplates a reasoned exercise of the courts' discretion taking into account all relevant factors” | 10 |
| 4 | Wildlands CPR v. United States Forest Service | green | “the catalyst theory assumes that a voluntary or unilateral change in an agency's position is induced by the complainant's lawsuit.” | 8 |
| 5 | N.Y.C. Apparel F.Z.E. v. United States Customs & Border Protection Bureau | green | “essentially codifies the so-called 'catalyst theory' for determining a fee request against the united states, under which a plaintiff is deemed to have 'substantially prevailed' for purposes of 552(a)(4)(e) if the 'litigation substantially caused the requested records to be rel…” | 6 |
A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.