Minor Victories Do Not Support an Award of Fees Under California's Private Attorney General Doctrine


In Center for Biological Diversity v. California Fish and Game Commission, 2011 DJDAR 6499 (2011), the California Court of Appeal for the First District rendered a decision clarifying an issue that comes up frequently under California’s so called “private attorney general doctrine.”

An environmental organization, the Center for Biological Diversity (the “Center”), filed suit challenging the California Fish and Game Commission's refusal to designate the American pika as eligible for endangered species protection under California’s version of the Endangered Species Act.

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