Third Circuit Vacates Fee Award In RCRA Lawsuit Against Honeywell

Offers of judgment may be made in the context of attorneys’ fee disputes under the fee-shifting provisions of the Resource Conservation and Recovery Act, the U.S. Court of Appeals for the Third Circuit has ruled, vacating the district court’s fee award (Interfaith Community Organization v. Honeywell International Inc., 3d Cir., No. 11-3813).

The Third Circuit vacated the award because it found the district court’s review of hours for which compensation was claimed inadequate.

The attorneys’ fee dispute arises from a decades-old RCRA citizen suit brought by the Interfaith Community Organization against the operators of a chrome manufacturing ...