In Purdue v. Kenny, — S.Ct. — (2010), Justice Alito authored an opinion holding that there is a strong presumption that the lodestar method of calculating attorneys’ fees in fee shifting statutes (in this case, 42 USC 1988) sufficiently compensates the attorney, and that a multiplier, while allowed, is permissible only in rare cases.   While Purdue involved a civil rights matter, the scope of the decision’s reach and impact on other fee-shifting statutes remains to be seen.