Consumer Class Actions: 19.3.7.5 Lodestar Multipliers in Common Fund Recoveries
When a lodestar calculation is used to determine or to cross-check the proposed percentage fee from a common fund, courts commonly approve a fee that is higher than the lodestar figure. “[M]ultipliers may reflect the risks of non-recovery facing counsel, may serve as an incentive for counsel to undertake socially beneficial litigation, or may reward counsel for an extraordinary result.”255