Goff, J.
Indiana’s Access to Public Records Act (APRA) is designed to promote transparency in government by giving the public access to most government records. Because APRA is enforced by private parties, it provides a mandatory attorney’s fee award to a party who “substantially prevails” in their APRA action. Christopher Nardi sued the Indiana Election Division (the Division) under APRA for three documents related to Indiana’s voter-registration system. The trial court ordered the Division to produce one of those documents. The trial court then concluded that Nardi substantially prevailed as to one of his three APRA requests, so it awarded him one-third of the fee he asked for.
We hold that because Nardi successfully obtained a wrongfully withheld public record, the trial court did not abuse its discretion in concluding that he substantially prevailed under APRA. But we remand to the trial court to recalculate attorney’s fees after considering the time Nardi’s counsel spent on the successful claim and whether the time spent on the unsuccessful claims was indivisible from the time spent on the successful claim.
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We first consider whether the trial court abused its discretion in concluding that Nardi “substantially” prevailed. On this issue, we conclude that the trial court did not abuse its discretion because, though Nardi only obtained one of the three requested records, he still successfully obtained a wrongfully withheld record. Next, we consider whether the trial court abused its discretion when it reduced Nardi’s attorney’s fee award to one-third of the fee requested. We conclude that it did. We thus reverse and remand to the trial court to recalculate attorney’s fees after considering how much time Nardi’s counsel spent on the successful claim and if the time spent on the unsuccessful claims is indivisible from the time spent on the successful claim.
I. The trial court did not abuse its discretion in concluding that Nardi “substantially” prevailed in his APRA request.
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Here, the issue is whether Nardi “substantially” prevailed, entitling him to mandatory attorney’s fees. Nardi argues he “substantially” prevailed because he obtained a judicial order for the contract, the parties litigated for two years, he successfully obtained the judge’s in-camera review of the documents, and he had no choice but to sue because the Division refused to disclose the contract even after the PAC recommended disclosure. The Division argues that Nardi did not “substantially” prevail because he only obtained one of the three documents he requested, and the document he did receive was highly redacted and mundane, telling him little about the voter-registration system and absentee voting.
A. Although Nardi did not obtain all the records he requested, the trial court did not abuse its discretion in finding Nardi substantially prevailed after he obtained a wrongfully withheld public record.
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The ordinary definition of ‘‘prevail’’ is “to gain victory,” and the technical definition is ‘‘[t]o obtain the relief sought in an action.’’ Prevail, Webster’s 3d New Int’l Dictionary 1797 (Phillip Babcock Gove et al. eds., 2002); Prevail, Black’s Law Dictionary 1380 (10th ed. 2014). But in the attorney’s fees provision of APRA, the adverb “substantially” modifies the word “prevails.” “Substantial” means “being that specified to a large degree or in the main” or “relating to the main part of something.” Substantial, Webster’s 3d New Int’l Dictionary 2280. Here, Nardi sought production of three records from the Division. Under the ordinary definition of “substantially,” Nardi could “substantially” prevail by obtaining the requested relief “in the main” but not to the full extent originally sought. Therefore, Nardi did not need to obtain all the requested documents to “substantially” prevail.
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Considering persuasive authority from other jurisdictions and precedent from our Court of Appeals, we hold that the trial court here did not abuse its discretion in finding Nardi “substantially” prevailed by obtaining a wrongfully withheld public record, even though he received only a portion of all requested records. When the Division failed to disclose the contract, despite the PAC’s recommendation otherwise, Nardi had no choice but to sue the Division to obtain the documents. The Division argued to the trial court that the documents were exempt from disclosure under Indiana Code section 5-14-3-4(b)(10), which covers “[a]dministrative or technical information that would jeopardize a record keeping system, voting system, voter registration system, or security system.” But the trial court determined that portions of the contract did not fall under the exemption and ordered the Division to provide Nardi a redacted version of the contract.
Because the Division wrongfully withheld portions of the contract, and because Nardi successfully obtained the redacted contract, the trial court did not abuse its discretion in concluding that he “substantially” prevailed under APRA.
B. We decline to adopt quantitative or qualitative measures in determining whether a party substantially prevails in an APRA request.
The Division advocates for the use of quantitative and qualitative measures to determine if a party “substantially prevails.” But these measures pose practical problems for trial courts. The Division argues that, from a quantitative approach, Nardi did not substantially prevail because he did not recover “most” of the requested records. Cf. Sullivan, 182 N.E.3d at 875–76 (concluding plaintiff “substantially prevailed” by obtaining “most” of the requested records). But even if a plaintiff does not recover most of the requested documents, they could have still obtained the documents most important to them. The documents obtained could also have more pages or provide more information than the documents withheld. A quantitative approach would also discourage plaintiffs from combining claims. Had Nardi filed three separate lawsuits, he would have quantitatively prevailed on the lawsuit for the contract because he would have technically received all the documents he requested. Measuring the ratio of successful to unsuccessful requests is therefore inefficient.
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Having determined that the trial court did not abuse its discretion in concluding Nardi “substantially” prevailed, we turn to the calculation of reasonable attorney’s fees.
II. Nardi may recover attorney’s fees for time spent on unsuccessful claims if it is indivisible from the time spent on the successful claim.
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To guide trial courts when calculating attorney’s fees under APRA where there are successful and unsuccessful claims, we offer the following analytical framework. The prevailing party that has “substantially” prevailed and seeks fees should present evidence to the trial court on the time spent on the successful claims and unsuccessful claims. The trial court should award attorney’s fees for the time spent on the successful claims. If the trial court determines that the time spent on unsuccessful claims is so closely related to the time spent on successful claims that the time is indivisible, the trial court may also award attorney’s fees for the unsuccessful claims.
Here, Nardi’s counsel insists he would have spent the same amount of time on the case had he only litigated the successful contract claim instead of all three claims because the Division’s common defense made the claims indivisible. Therefore, we remand to the trial court to make fact determinations on the relatedness of the claims. If it finds Nardi’s unsuccessful claims indivisible from the successful ones, the trial court may award attorney’s fees for all claims.
Conclusion
Nardi requested three documents from the Division, and after over two years of litigation and an in-camera review, Nardi obtained a judicial order for one of the documents. We hold that the trial court did not abuse its discretion in concluding that Nardi “substantially” prevailed in his APRA request. But we remand to the trial court to recalculate the fee award after considering how much time Nardi spent on his successful claim and whether the time spent on the unsuccessful claims was indivisible from the time spent on the successful claim. Affirmed in part, reversed in part, and remanded for further proceedings. [Footnote omitted.]
Rush, C.J., and Massa, Slaughter, and Molter, JJ., concur.