In what circumstances will a court grant an application for attorneys' fees and costs in a class action?

In Everglades Drainage League v. Napoleon B. Broward Drainage Dist., D.C., 1918, 253 F. 246, appeal dismissed 251 U.S. 567, 40 S.Ct. 219, 64 L.Ed. 418, a three-judge court held that the class suit was proper even though each complainant was interested in the subject matter in different amounts and was differently connected with the whole dispute.

In Sprague v. Ticonic Nat. Bank, 1939, 307 U.S. 161, 59 S.Ct. 777, 83 L.Ed. 1184, the court had before it an application for attorneys' fees and costs over and above the regular taxable costs. The action was not brought as a class action, but it was asserted that the efforts of plaintiff had nevertheless resulted in benefit to a class whose rights to a common fund were established by the litigation. The fees and costs were allowed on the basis that plaintiff had established the rights of others to a common fund, under the doctrine of stare decisis. 307 U.S. page 166, 59 S.Ct. 777.