This decision holds that Trustees v. Greenough (1882) 105 U.S. 527, and Central Railroad & Banking Co. v. Pettus (1885) 113 U.S. 116 prohibit routine awards of incentive payments to named plaintiffs from a common fund class recovery.  Greenough upheld an award of attorneys’ fees and litigation expenses but rejected as without legal basis an award for the lead plaintiff’s “personal services and private expenses”—in particular, the yearly salary and reimbursement for the money he spent on railroad fares and hotel bills.  Pettus reiterated this holding.  A modern day incentive award to a named plaintiff is compensation for the named plaintiff’s services.  That compensation is forbidden by the rule adopted in Greenough and Pettus.