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v. Eckerhart, 461 U.S. 424, 433 (1983). The resulting figure,
commonly referred to as the lodestar, “‘has, as its name
suggests, become the guiding light of * * * [the Supreme Court’s]
fee-shifting jurisprudence.’” Gisbrecht v. Barnhart, 535 U.S.
789, 801 (2002) (quoting Burlington v. Dague, 505 U.S. 557, 562
(1992)); see also Hensley v. Eckerhart, supra at 433 n.7 (“The
standards set forth in this opinion are generally applicable in
all cases in which Congress has authorized an award of fees to a
‘prevailing party.’”).
2. Hours Reasonably Expended
a. The Limited Success Factor
In Hensley, the Supreme Court recognized that the
determination of hours reasonably expended extends beyond
considerations of efficiency and documentation. As the Court
stated:
If * * * a plaintiff has achieved only partial or
limited success, the product of hours reasonably
expended on the litigation as a whole times a
reasonable hourly rate may be an excessive amount.
* * *
* * * That the plaintiff is a “prevailing party”
therefore may say little about whether the expenditure
of counsel’s time was reasonable in relation to the
success achieved. * * *
Hensley v. Eckerhart, supra at 436. Professor Sisk sometimes
refers to this aspect of reasonableness as the limited success
factor. Sisk, “The Essentials of the Equal Access to Justice
Act: Court Awards of Attorney’s Fees for Unreasonable Government
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