Offers of judgment may be made in the context of attorneys' fee disputes under the fee-shifting provisions of the Resource Conservation and Recovery Act, the U.S. Court of Appeals for the Third Circuit has ruled, vacating the district court's fee award (Inter-faith Community Organization v. Honeywell International Inc., 3d Cir., No. 11-3813, 6/4/13). The Third Circuit vacated the award because it found the district court's review of hours for which compensation was claimed inadequate.
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