TJOFLAT, Circuit Judge:
The sole issue in this appeal is whether the district court erred as a matter of law when it refused to award an attorney's fee to a union member who successfully obtained an injunction compelling his union to comply with his reasonable request for a campaign mailing to the union membership. Because the district court misapplied the "common benefit" exception of the "American rule" disfavoring the allowance of attorneys' fees in the absence...
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