California, United States of America
The following excerpt is from La Investment v. Banuelos, B260151 (Cal. App. 2016):
The remaining issue is whether the Attorney Defendants are entitled to recover attorney fees for their success in striking the defamation claim. "The teaching of Trope and its progeny is that law firms and attorney litigants are precluded from recovering attorney fees for self-representation. [Citations.]" (Soni v. Wellmike Enterprise Co. Ltd. (2014) 224 Cal.App.4th 1477, 1488.) On the other hand, "attorney litigants who retain other attorneys to represent their personal interests may recover attorney fees, just like nonattorney litigants." (Ibid.)
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