Can a private attorney general be awarded attorneys' fees?

^3. Prior to the enactment of section 1021.5, trial courts could award attorneys' fees to a litigant under the private attorney general doctrine if the court determined that the litigation "resulted in the vindication of a strong or societally important public policy, that the necessary costs of securing this result transcend the individual plaintiff's pecuniary interest to an extent requiring subsidization, and that a substantial number of persons stand to benefit from the decision." (Serrano v. Priest (1977) 20 Cal.3d 25, 45.) The doctrine rested "upon the recognition that privately initiated lawsuits are often essential to the effectuation of the fundamental public policies embodied in constitutional or statutory provisions, and that, without some mechanism authorizing the award of attorney fees, private actions to enforce such important public policies will as a practical matter frequently be unfeasible." (Woodland Hills, supra, 23 Cal.3d at p. 933.)