Dickenson v. Johnson

(1) Whether district courts may be required to use the inherently subjective and effectively unreviewable factors to determine common-fund fee awards set out in Johnson v. Georgia Highway Express, Inc. despite the court"s rejection of the that approach in Perdue v. Kenny; (2) whether district courts may be required to calculate common-fund attorney"s fees only as a percentage of the fund, or may instead award fees based on the attorney"s lodestar; and (3) whether the U.S. Court of Appeals for the 11th Circuit may mandate that district courts adopt a 25% "benchmark" for percent-of-fund attorney"s fee awards.