There was an interesting Second Circuit case last year criticizing the "lodestar" method, and claiming it should be abandoned because it creates confusion. Arbor Hill Concerned Citizens Neighborhood Association v. County of Albany (2d Cir. 2008) 522 F.3d 182. Judges should use their "considerable discretion, to bear in mind all of the case-specific variables that we and other courts have identified as relevant to the reasonableness of attorney's fees in setting a reasonable hourly rate" so that fee awards should approximate market rates. You can download our copy of Arbor Hill here in pdf. Maybe we should have posted this yesterday, too, in keeping with the theme.