In what circumstances will attorney fees be awarded under the private-attorney general theory?

In Serrano v. Unruh (1982) 32 Cal.3d 621, 186 Cal.Rptr. 754, 652 P.2d 985, we held that an attorney fee award under a statute codifying the private-attorney-general theory (Code Civ.Proc., 1021.5) ³ "should ordinarily include compensation for all hours reasonably spent, including those relating solely to the fee." (32 Cal.3d at p. 624, 186 Cal.Rptr. 754, 652 P.2d 985.) We reasoned that the rationale of the private-attorney-general theory--i.e., that private litigation to enforce important public policies should be actively promoted by awarding compensation to the successful plaintiffs' attorneys--"will often be frustrated, sometimes nullified, if awards are diluted

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