Does the Fifth Circuit's rule that all federal fee-award laws must be read identically contravene this Court's decision in Fogerty v. Fantasy Inc.?

QUESTIONS PRESENTED 1. Does the Fifth Circuit’s rule that all federal fee-award laws must be read identically (i.e., absent express textual differences) contravene this Court’s decision in Fogerty v. Fantasy Inc., 510 U.S. 517 (1994)—and Seventh Circuit precedent implementing Fogerty—which call for individual analysis of federal fee-award laws based on each law’s respective text, structure, history, and purpose? 2. Does Congress’s use of the word “incurred” in a fee-award law refer solely to a legal obligation to pay attorney fees, as the Fifth Circuit has ruled, or does “incurred” also refer to any expended lawyer time, as the Seventh Circuit has ruled, thus allowing a feeaward law to compensate the work of pro bono attorneys, in-house attorneys, government attorneys, and self-representing attorneys alike? 3. Does a fair reading of the federal Freedom of Information Act (FOIA) and its fee-award provision, 5 U.S.C. § 552(a)(4)(E), allow attorney-fee awards in “any case” under FOIA where the “complainant” has substantially prevailed—including cases where the complainant is a self-representing attorney?