United States Third Circuit

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Interfaith Community Organization v. Honeywell International, Inc, 11-3813

The district court's declaration that the offers of judgment pursuant to Fed. R. Civ. P. 68 were null and void, is reversed, and the attorney's fee award is vacated and remanded, where: 1) Rule 68 offers of judgment may be made in the context of attorney's fee disputes under the fee-shifting provisions of the Resource Conservation and Recovery Act; and 2) though the district court did not clearly err with respect to the appropriate hourly rates in this case, the district court's finding with respect to the number of hours claimed by counsel lacks sufficient explanation.

Appellate Information

  • Decided 06/04/2013
  • Published 06/04/2013




  • United States Third Circuit