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Legal fees in a prisoner civil rights case filed shortly before Congress capped such awards in 1996 should be fixed at the more generous pre-capped rates for work done before the law’s effective date, and fixed at the capped rates for work done afterward, a federal judge in Manhattan has ruled.

Writing on an issue that has divided courts around the country and is pending before the U.S. Supreme Court, Southern District Judge John S. Martin Jr. proposed the hybrid fee award in the case of a New York prisoner, Bobby Williams, confined in medical keeplock for 589 days for refusing to take a tuberculosis test.

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