Last month, the United States Court of Appeals for the District of Columbia decided an attorneys fees issue where the document was released subsequent to the filing of the lawsuit, but the district court ruled that the government would have been able to withhold the document if it had wanted to.
At issue before the Court of Appeals was whether the requester was entitled to attorney fees in this case (both sides agreed he was eligible). The Court decided that because the government's decision to withhold the document would have been proper if the district court had made a decision on the merits, the requester was not entitled to attorney fees. Nor did any other provision of the 2007 FOIA amendments make an award of attorney fees proper in this case. The case can be found here.
Fortunately, the decision to make a discretionary disclosure of documents usually comes about before a case is briefed in the district court, so this situation may not arise that much.