Sukumar

*454 Litigation under the Public Records Act (PRA) ( Gov. Code, 1 § 6250 et seq. ) is one of the rare instances where a losing party may still be deemed a prevailing party entitled to an attorney fee award. This is because the plaintiff has prevailed within the meaning of the PRA when he or she files an action that "results in defendant releasing a copy of a previously withheld document." ( Belth v. Garamendi (1991) 232 Cal.App.3d 896 , 898, 283 Cal.Rptr. 829 ( Belth ).)

Thus, a plaintiff need not achieve a favorable final judgment to be a prevailing *421 party in PRA litigation. A defendant's voluntary action in providing public records that is induced by plaintiff's lawsuit will still support an attorney fee award on the rationale that the lawsuit " 'spurred defendant to act or was a catalyst speeding defendant's response.' " ( Belth, supra, 232 Cal.App.3d at p. 901 , 283 Cal.Rptr. 829 .)

In this PRA litigation, Ponani Sukumar appeals an order denying his motion for prevailing party attorney fees against the City of San Diego (City). We reverse because the undisputed evidence establishes the City produced, among other things, five photographs of Sukumar's property and 146…