- As a Pro se Attorney, the Plaintiff was Not Entitled to Attorney’s Fees.
- July 13, 2017
A.V. v. Ashrafi – Docket No. A-5241-14T3 – (N.J. Super. App. Div. Apr. 3, 2017)
The plaintiff alleged that the defendants, including Grodeck, violated his civil rights under the New Jersey Civil Rights Act. Mr. Grodeck is an attorney and represented himself pro se. After the plaintiff’s complaint was dismissed, Grodeck sought counsel fees as a prevailing party pursuant to the New Jersey Civil Rights Act. The Appellate Division held that a pro se attorney who prevails in an action brought under the NJCRA could not recover counsel fees under N.J.S.A. 10:6-2(f) of the New Jersey Civil Rights Act, N.J.S.A. 10:6-1 to -2. In the alternative, the court established that, because Grodeck was a party defending himself against, as opposed to prosecuting, an action brought under the Act, he could not be a prevailing party.