Despite the recent admonition of the Supreme Court that a "request for attorneys' fees should not result in a second major litigation,"12 the courts have been frequently called on to interpret the often ambiguous language of the EAJA. The U.S. Court of Appeals for the Sixth Circuit has not been spared this difficult chore. While the 1985 amendments have clarified some provisions of the Act and affected some major decisions in the Sixth Circuit, the recent changes have also left other previously settled areas in a state of flux. This article will review the Sixth Circuit's EAJA decisions from 1983-1987, focusing upon the areas most frequently subject to judicial interpretation.
Reingold, Paul D. "Making Uncle Sam Pay: A Review of Equal Access to Justice Act Cases in the Sixth Circuit, 1983-1987." M. Geer, co-author. U. Tol. L. Rev. 19 (1988): 301-30.