The order to pay originated from an open records case from the conservative group Judicial Watch. The group asked Willis’s office to provide it with documents pertaining to possible communications with Department of Justice special counsel Jack Smith, who led a separate investigation into Trump’s actions surrounding his efforts to overturn the results of the 2020 election with the Jan. 6 attack on the Capitol.

Earlier this month, Superior Court of Fulton County Judge Robert McBurney ruled that Willis’s office violated Judicial Watch’s open records request by categorizing identifying responsive documents as exempt from the request but previously said none of these documents existed.

“Even if the records prove to be just that — exempt from disclosure for sound public policy reasons — this late revelation is a patent violation of the ORA. And for none of this is there any justification, substantial or otherwise: no one searched until prodded by civil litigation,” he wrote.

McBurney found Willis’s office liable for paying Judicial Watch $19,360 in attorney’s fees related to the group’s efforts in the open records request. Willis was additionally ordered to pay $2,218 in other related legal expenses.

“Fani Willis flouted the law, and the court is right to slam her and require, at a minimum, the payment of nearly $22,000 to Judicial Watch,” Judicial Watch President Tom Fitton said in a statement.

In December, McBurney, in a separate order, said because Willis did not provide a timely response to the court, she would have to hand over records of all communications with Smith and the Jan. 6 committee to the group.

While Willis had said she was not properly served, McBurney said despite the initial confusion on the court docket, Willis “never offered up a meritorious defense.”

Willis denied any coordination with Smith. Following the election, Smith dismissed the charges to avoid interfering with the long-standing tradition of the DOJ not investigating a sitting president.