The 2nd Circuit spread consternation in April when it seemed to add additional grounds for reducing fee awards to attorneys who handle civil rights cases. Thursday, the panel denied a request for a rehearing on the fee issue, but it added a footnote. Reaction among lawyers involved in the case was varied, with some hailing the footnote and others saying it will only contribute to the confusion.
2nd Circuit Attempts to Clarify Fee Rule in Civil Rights Cases
New York Law Journal
July 13, 2007