Seventh Circuit Judge Richard Posner savaged a district court for approving a class action settlement that paid lead class counsel an $11 million fee while providing class members with benefits worth, in Judge Posner's reckoning, no more than $8.5 million. Eubank v. Pella Corp., No. 13-2091 (7th Cir. June 2, 2014).

The fact that

Dell Logo

The Fifth Circuit for a long time has seemed to insist on paying class counsel on a pure lodestar basis — hours x hourly rates. It looked to have stuck itself to the old-style lodestar method under Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974).

That contrasts with other circuits'