In 2007, Congress amended FOIA to partly overrule Buckhannon Board & Care Home, Inc. v. West Virginia Dept. of Health & Human Resources (2001) 121 S.Ct. 1835 and allow the plaintiff to recover attorney fees on the catalyst theory in FOIA cases.  The 2007 amendment allows a FOIA plaintiff to prove eligibility for a fee award by either (a) he obtained relief through a “judicial order, or an enforceable written agreement or consent decree, or (b) the agency voluntarily or unilaterally changed its position and his suit was not insubstantial.  This decision holds that the plaintiff must show a causal connection between his suit and the agency change of position under the second of these alternatives, not the first.  So, in this case, plaintiff is eligible for a fee award because the DoD eventually produced requested records pursuant to a court order entered in the case.  It did not matter that the DoD released the records and stipulated to the order simply because President Trump revealed some of the records for his own purposes having nothing to do with the suit.