The trial court's order for payment of attorney fees and costs by plaintiff, a newspaper publisher, to defendant-district that complied with a burdensome request for documents under the California Public Records Act (PRA) is reversed and remanded, where: 1) plaintiff is not the prevailing party in the PRA action; and 2) although plaintiff was unsuccessful in obtaining withheld documents or e-mails in native format, his PRA petition was not frivolous.