Federal Circuit: Starry Associates v. US

The statute authorizing an award of fees does not contemplate egregiously dilatory agency conduct as a basis for increasing the base rate of compensation; as the "special factor" basis is listed with a "cost of living" basis, the statute authorizes increases in the award where the base rate is insufficient due to the character of the representation.  Because noscitur.

http://www.cafc.uscourts.gov/sites/default/files/opinions-orders/17-2148.Opinion.6-22-2018.pdf