Third Circuit: Bernie Clemens v. New York Central Mutual Fire

Not an abuse of discretion for court to dismiss petition under fee-shifting statute in its entirety where counsel's performance was sub-par, timekeeping records were vague, there was insufficient proof of local prevailing rates, and plaintiff asks for 900k in fees on a 100k award after a four day trial.

http://www2.ca3.uscourts.gov/opinarch/173150p.pdf